HomeMy WebLinkAbout96-05212
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MARITAL PROPBRTY AHD SBTTLBMENT AGREBMENT
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THIS AGREEMENT, made this 2 "I day of January, 1997, by
and between Kimberly S. Riley, party of the first part, hereina-
fter referred to as "Wife", and Daniel T. Riley, party of the
second part, hereinafter referred to as "Husband".
WITNESSETH:
WHEREAS, the parties hereto are husband and wife,
havinq been _rried on October 14, 1989 in East Hampton, Long
Island, New York, separating on August 28, 1995: and
WHEREAS, there has been a child born of the parties
durinq aarriage, namely ca.eron Hunter Riley, 0.0.8. 04/0)/92,
hereinafter referred to as "child": and
WHEREAS, certain differences have arisen by and between
the partie. as a result of which they have now separated, living
independent and apart from one another, and the partie. hereto
are de.irous of settlinq fully and finally their respective
financial and property rights and obligations as between each
other InclucUnq, without limitation by specification: the
HttliftCJ of all utters between the. relatiftCJ to the ownersbip
and equitable cUstribution of real and personal property, the
HttUftCJ of all utters between them relaUftCJ to the past,
present and future support and/or aalntenance of tM Child, the
illPl.....tatlon of C\Jatody/vlalt&tlon urang...nts fol' the minor
child of the perti.., tM ..ttliftIiJ of aU ..U.ra between th..
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relating to the past, present and future support, alimony and/or
maintenance of Wife by Husband or of Husband by Wife; and in
general, the settling of any and all claims and possible claims
by one against the other or against their respective estates.
WHEREAS, the parties being fully advised as to their
respective rights, duties and obligations gruwing out of their
marital status, particularly with respect to the relevant sec-
tions of the Oivorce Code, Act of April 2, 1980, P.L. 63, Act No.
26, as amended, 23 P.S. 3101 et sea., and being fully aware of
their right to consult with or having consulted with their
respective legal counselor advisors, namely Andrew c. Sheely,
Esquire, Attorney for Wife, and Husband, pro se, being fully so
advised consult with an attorney, and acknowledging the oppo-
rtunity and ability to request a full and complete disclosure of
income and assets from the other, and reviewing this Agreement,
have co.. to an agreement as to each and all of their said
_tter. of property and relations: and
WHEREAS, Wife has filed a Complaint in Oivorce, said
Complaint beinq docketed in the Prothonotary'. office of CUmber-
land County, Pennsylvania, at No. 96 - 5212.
NOW, THEREFORE, in consideration of the above recital.
and the mutual covenants hereinafter .et forth, each of the
partie. hereto intending to be legally bound hereby by afUdnq
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their hands and seals agree as follows:
1. ADVICE OF COUNSEL
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 effect in advance of
the date set forth above to permit such independent review. Each
party acknowledges that he or she has had the opportunity to
receive independent legal advice from counsel from his or her
selection, and that each fully understands the facts and has been
fully informed as to his her or her legal rights and obligations,
and each party acknowledges and accepts that this Agreement is,
and the circumstances, fair and equitable, after having the
opportunity to receive such advice and with such knowledge, and
that execution of this Agreement is not the result of any im-
proper or illegal agreement or agreements. In addition, each
party hereto acknowledge. that he or she has had the opportunity
to be fully 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 all marital rights of the parties
including divorce, alimony, alimony pendente lite, equitable
distribution of aU marital property or property owned or pos-
sessed individually by the other, counsel fees and cost. of
litigation and. fully knowing the same and having the opportunity
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to be fully advised if his or her rights thereunder, each party
hereto still desires to execute this Agreement, acknowledging
that the terms and conditions set forth therein are fair, just
and equitable to each of the parties, and waives his and her
respective right to have the Court of Common Pleas of CUmberland
County, or any other court of competent jurisdiction, make any
determination or order effecting the respective parties rights to
a divorce, alimony, alimony pendente lite, equitable distribution
of all marital property, counsel fees and costs of litigation.
2. SEPARATION
It shall be lawful for each party at all times
hereafter to live separate and apart from each other in such
place or places as he or she may from time to time choose.
3. INTERFERENCE
Each party shall be free from interference, authority
and control, direct or indirect, by the other as fully as if he
or &he were single and unmarried. Neither shall molest the other
or their respective families, or compel or endeavor to compel the
other to cohabitate or dwell with him or her, or to in any way
harass or .align the other or their respectlve fa.ilie..
4 . WAIVER or CLAIMS ACAtNST ESTATES
Except as otherwise provided bentn, Husband rel1n-
qui.nea his inchoate intestate right and his r19bt to act a. .
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personal representative in the estate of Wife, and Wife relin-
quishes her inchoate intestate right and her right to act as a
personal representative in the estate of Husband. Each of the
parties hereto by their presents, for himself or herself, his or
her heirs, executors, administrators or assigns, does remise,
release, quit-claim and forever discharge the other party hereto,
his or her heirs, executors, administrators or assigns or any of
thea, of any and all claims, demands, damages, actions, causes of
actions, suits, at law or equity, of whatsoever kind or nature,
for or because of any matter or thing omitted or suffered to be
done by .aid other party prior to and including the date hereof,
except th.t this release shall in no way exonerate or discharge
either party hereto from the oblig.tions and promises made and
imposed by reason of this Agreement and shall in no way affect
any cause of action in absolute divorce which either party may
h.ve aqain.t e.ch other.
5. MARITAL PROPERTY
The parties hento acknowledge that durlnq their
..rri.qe they have .cquired, individually or jointly, various
....t. and property, inclUding ai.cellaneou. bank account.,
peraonal Pl'Operty, construction tool. and equipment, actor
vsbiclea, computera, el~tronic equlpment, guns, archery equip-
ment, other aportlnq lJOOd. .nd other alaceUaft4lO\la U.bUlt1..
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and credit card debt.
Husband and Wife acknowledge that they are aware of
their respective rights pursuant to the Oivorce Code of 1980, as
amended, to obtain formal valuations or appraisals of the marital
residence, and other items of marital property. The parties
hereby waive any necessity for completing or attaching any
financial disclosure(s). Each party further acknowledges the
opportunity to attach a full and complete financial disclosure
and that such disclosure is not desired to effectuate a faIr and
equitable resolution of their marital rights, duties and obliga-
tions as provided in the Oivorce Code of 1980, as a..nded.
6. PERSONAL PROPERTY
The parties hereto autual1y agree that they have
effected a satlsfactory division of the furniture, household
furnishings, appliances and other household personal property
between them, and they autually a9ree that each party shall froa
and after the date hereof be the sole and separate owner of all
such tanqible personal property presently in his or her posse.-
sion, whether aaid property is hentofore owned jointly or
individually by the parties hereto, and thI. A9ree..nt shan have
the effect of an a.sIgnment or bill of sale froa each party to
the other for such property as My be in the individual poea..-
slons of each of the partie. hereto.
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7. MOTOR VEHICLES
The parties hereto agree that Husband shall be entitled
to have the sole and exclusive control, benefit, use and title of
the 1989 Ford 150 Van, or the proceeds thereof, and that he shall
further hold wife harmless from and assume full responsibility
for any liability for the 1989 Ford 150 Van. The parties hereto
agree that Wife shall be entitled to have sole and exclusive
control, benefit, use and title of the 1992 Toyota Corolla, or
the proceeds thereof, and that she shall hold Husband harmless
from and assume full responsibility for car payments to the
Suffolk NatIonal Bank, insurances and liability for such motor
vehicle.
The parties hereto agree that titles to the motor
vehicles shall be transferred within thirty (30) days from the
date of this Agreement to the party receiving title, if
appliCable.
I. MISaT.TJoNmtlS
(A) Tbe parties hereto acknowledge and agree that any
and all aavinqs and checUnq accounts, as well as certificate. of
deposit and other investunt account., owned by the. jointly or
alnqly, have been divided to their mutual and lndividual aatia-
faction.
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(8) Neither party hereto shall make a claim upon the
other for accumulated pension, profit-sharing, retirement sup-
port, retirement benefits, insurance policies, IRA's, or any
retirement-related benefits, exceptinq only those benefits set
forth in the Agreement.
(e) The parties hereto acknowledge and agree that any
and all life insurance policies owned by them jointly or singly
have been divided to their mutual and individual satisfaction.
Each party hereto acknowledges that they have in their sole
possession those policy or policies of life insurance which they
intend to keep and retain as their sole and exclu.ive property
and, further, each party shall have the right to designate the
beneficiaries of said policies.
(0) The division of ex1stinq ..rital property is not,
except as otherwise expressly provided herein, intended by the
partIe. to constitute in any way, a .ale or exchange of as.et.
and the division Is being affected without the Introduction of
out.ide funds or other property not constituting a part of the
..dtal ..tate. All a part of an equitable division of the
aarital properties and the marital settlement herein contained,
the parti.. bereto aqne to save and hold each other harml...
fro. all lncc.. taxes a..e.nd avalnat the otber re.ultinq fro.
tM cUvi.1Oft of the property as bueln provided.
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(E) Each party represents and warrants to the other
that he or she has not incurred any debt, obligation or other
liability, other than those described in this Agreement, on which
the other party is or may be liable. A liability not disclosed
in this Agreement will be the sole responsibility of the party
who has incurred or may hereafter incur it, and such party agrees
to pay it as the same shall become due, and to indemnify and hold
the other party and his or her property harmless from any and all
such debts, obligations and liabilities.
(F) Each party represents and warrants to the other
that each shall file separate income tax returns for tax year
1996 and thereafter. Information maintained by one party which
is necessary to co.plete any subsequent income tax return by the
other party shall not be unreasonably withheld upon the request
of either party.
10. DEBTS OF HUSBANO AHO WIFE
Husband and Wife acknowledge that they have incurrecl
various aarital, (joint and separate) debts prior to separation.
At the date of separation, Husband and Wife were indebted to the
following entiti.s in the follovlng approximate amounts:
IIDtl Amount of Debt
A. Citibank vi.. $5,000.00
I. Unnployaent Insurance Dlvision $2,100.00
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Wife represents and warrants to Husband that from the
signing of this Agreement and in the future Wife will pay for
such debts and assume full responsibility for such debts in
accordance with this paragraph. Husband agrees that he shall pay
Wife a total amount of $750.00 to apply to such debts, at the
minimum rate of $125.00 a month until such debt in the amount of
$750.00 is fully satisfied. Upon payment of the amount of
$750.00, Wife shall hold Husband harmless from any and all claims
or d8llllnds made against her by reason of such debts. Payment of
the sua of $750.00 from Husband to Wife shall occur prior to Kay
1, 1997.
The parties hereto agree that any and all obligations
incurred subsequent to the date of separation, said date being
August ~8, 1995, shall be the sole and individual responsibility
of the party incurrlng the obligation.
Husband represents and warrants to Wife that from the
signing of this Agreement and in the future he will not contract
or incur any debt or liability for which Wife or her estate .1ght
be responsible and shall indemnify and save harmless Wife from
any and all clai.s or deaanda aade against her by reason of debts
or oblIgatlons incurred by hi..
Wife repreHntt! and warrants to Husband that from the
algnlng of this Agreement and in the future she will not contract
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or incur any debt or liability for which Husband or his estate
might be responsible and shall indemnify and save harmless
Husband from any and all claims or demands made against him by
reason of debts or obligations incurred by her.
11. CUSTODY.
Husband and Wife acknowledge that a prior Agreement
dated October 5, 1995 has provided the parties with a general
custody schedule for approximately one year. It is the specific
intent of Husband and Wife to modify the terms of the prior
custody agreement to reflect the present custody arrangement
which has been changed due to transportation and traveling
concerns between the State of New York and the Commonwealth of
Pennsylvania. Husband and Wife acknowledge that they have modif-
ied the prior Agreement dated October 5, 1995, and desire that
the provisions of this paraqraph supersede any prior Order of
Court or agreement of the parties, as follows:
(A) Mother and Father shall have shared legal custody
of the chilcl, meaning that both parents shall make joint
decisions concerning the child's education, serious aecllcal
decisions affecting the child and reliqious instruction, and
(8) Mother shall have priaary physical custody of
the child: and
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(e) Mother and Father agree that Father shall have
periods of partial physical custody on the following basis:
(i) On every third (3rd) weekend, commencing at
9:00 p.m. on Friday, and continuing through Sunday
evening at 6:00 p.m.; and
(ii) On an alternating Holiday basis, commencing
with Thanksgiving in 1996. For purposes of this
Agreement, Holidays shall be defined as Thanksgiving
Day, Christmas Day, New Years Oay, Easter Holiday,
Memorial Oay, Fourth of July and Labor Day. In the
event a Holiday falls on a Friday or Monday prior to or
following the alternating custody period, such custody
period shall be adjusted to allow for a longer custody
period in accordance with the alternating custody
period: and
(iii) In the event an alternating custody period
would occur on a holiday, the parties agree that the
alternating custody period shall be modified to conform
with holiday contact period as set forth above.
(iv) Father shall have thirty (30) days of tem-
porary, partial custody as a summer vacation with the
child. A period of partial custody within the thirty
days shall not exceed fourteen (14) days. In the event
rather desires partial custody with the child as a
summer vacation, he shall provide Mother with notice of
such intention within thirty (30) days of the requested
time period and submit such notice to Mother prior to
June 1 of the appropriate year. Father shall reaain
responsible for all expenses incurred by the child
during his summer vacation and shall provide Mother
with all telephone numbers where the child can be
reached during such period.
(V) In addition to the dates and times set forth
above, the child .ay spend Mother's Day with Mother and
rather's Day with rather, if conVenient and aqre8able
to both parties.
(vi) And any other times as the partie. may agree.
(0) All pick-Ups and drop-offs Involving the Child
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shall occur at a mutually agreed upon location in Fort Lee,
New Jersey, or any other location agreed upon by the par-
ties.
(E) The parties will keep each other immediately
advised to any emergencies concerning the child and shall
further take any necessary steps to insure that the health
and well being of the child is always protected. The parties
shall provide each other with all home and work telephone
numbers, as well as current addresses for the residence of
the child. Both parties further agree to allow each other to
speak with the child at any and all reasonable times as set
forth below.
(F) Neither parent shall do anything which may estrange
the child from the other party, or injure the opinion of the
child as to the other party, or which may hamper the free
and natural development of the child's love or affection for
the other party.
(0) Mother and Father agree that each shall cOllllUnicate
to each other through one-another whenever po.sible in
accordance with the teru set forth In this Agre...nt and to
avoId uslnq child as a liaison to coaaunlcate with each
otber a. to oral ~ificatlona of this Agre..ent.
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(H) Mother and Father agree that there shall be reason-
able telephone access between the child and the non-cus-
todial parent. The parties agree to endeavor to place
telephone calls to the child between 7:00 and 9:00 p.m., so
as not to interfere with dinner or bedtime.
(I) Should Father predecease the child, Mother shall be
entitled to sole legal and physical custody of the child
without interference from Husband's family or friends in
accordance
~e child,
~)t1.~ical custody
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with applicable law. Should Mother predecease
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Methet shall be entitled to sole leqal and
of the child without interference from
or friends in accordance with applicable
law.
(J) In the event Father or Mother relocate to a new
location during the term of this Agreement, the relocating
party shall provide thirty (30) days notice of the decision
of the notice. Upon receipt of such notice, the parties
sball mutually discuss an agreed upon piCk-up and delivery
location, if possible, and any modlfications to this CUstody
Agre...nt sball be discussed at such time.
(I) The partie. agr.e that the within Agreement sball
be reduced to an Order of COUrt and that eitber party My
petition any COUrt with appropriate jurledlcUon over tM
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child should circumstances change and either party desire
modification of this Agreement.
12. SUPPORT FOR CHILD
A. Child SUDDort Husband and Wife acknowledge that a
prior Agreement dated October 5, 1995 has provided the parties
with a general child support payment schedule for approximately
(1) one year. It is the specific intent of Husband and Wife to
modify the terms of the prior child support payment agreement to
reflect the present financial interests of the parties. Husband
and Wife acknowledge that they have modified the prior Agreement
dated OCtober 5, 1995, and desire that the provisions of this
section supersede any prior Order of Court or agreement of the
partie., as follows:
(i) Husband acknowledges that he shall pay child
support in the amount of $800.00 per month, commencing on
November 1, 1996, payable to Wife for the benefit of the
minor child. All payments are due on the first day of each
month and in no circuastance shall payments be later than
the tenth (lOth) day of each IIOnth. In the event payment.
are late, Wife shall have the option to petitlon for child
support in accordance with subpara9raph B a. indicated below
and require that any child support enforcement a~ncy
actainiater tM provls1ons of this Acal'8...nt or any s\lbee-
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quent modifications thereto, with the costs of such enforce-
ment to be paid for by Husband.
(ii) Husband shall continue to pay child support in the
amount of $800.00 per month until April 1, 1997, when the
amount of child support shall decrease to an amount of
$575.00 per month. Commencing on April I, 1998, an annual
cost of living adjustment equal to two and one-half percent
(2.5\) shall be added to the payment of child support of
$575.00 or any additional amount agreed upon thereafter.
(iii) Husband shall pay for any and all reasonable
school and sports related extracurricular expenses incurred
by Cameron, including expenses for uniforms, sports gear,
shoes, equipment.
(iv) Husband and Wife agree and acknowledge that these
amounts are presently sufficient for child support and day
care expenses associated with the proper support and aain-
tenance of the ainor child. Child support shall continue
through the child's graduation fro. high school or emancipa-
tion, Whichever occun firat.
(v) Wlfe shall aaintaln the chlld'. health insurance,
provided she is able to obtain such health insurance tMlne-
fita for the child at a reasonable cost. In the event any
health or medical expenses an not paid by Wife's insurance,
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Husband and Wife agree to share equally any unreimbursed
medical or health expenses incurred by the child.
B. Modification of child SUDDort
Notwithstanding the terms of this Section and this Agree-
ment, Husband and Wife understand that circumstances may neces-
sitate an adjustment in the amount of support either upwards or
downwards, depending upon the child's circumstances and the
respective incomes or earning capacities of the parties hereto in
accordance with general support standards. In the event Husband
and wife cannot agree upon the amount of child support at any
ti.. hereafter, Husband and Wife agree that nothing set forth in
this paragraph or this Karital Property and Settle.ent Agreement
shall prejudice the right of .ither party to file a petition for
modiflcation of the amount of child support, at any ti.e, in any
Court of appropriate jurisdiction, if necessary. It is the
speCific intent of the parties that this Agre..ent is designed to
avoid the present filing of foraal child support proceedings
only, and any future award of child support will be qoverned by
the applicable support quidelinea and case law.
However, in the event of re..rriage, the income of the
spouse of Wife or Huaband shall not be directly consldered In
deteralninq any child support avard, and it is the intention of
Husband and Wife that their respective incomes or eamlnq capacl-
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ties shall be the primary consideration in determining a child
support payment.
c. Colleae SUDDort
Although no binding provisions are set forth in this
Marital Property and Settlement Agreement to require payment for
the child's college support, Husband and Wife recognize that a
college support obligation could exist in the future. While
Husband and Wife recognize such potential responsibility, no
provisions requiring either party to pay for college support are
set forth in the Marital Property and Settlement Agreement due to
the status of the law in Pennsylvania and to the variety of cir-
cumstances which could arise in the future. Nonetheless, Husband
and Wife acknowledge that elther party may contribute to the
child's college support In the future and/or set up college funds
for such potential future Obligation for the child's benefit.
13. ALIMONY. SUPPORT ANO MAIN'l'ENANCE
Both parties acknowledge and agree that the provisions
of this Agreement providing for equitable distribution of marital
property are fair, adequate and satisfactory to the. and are
accepted by the. in lieu of and in full and final satisfaction of
any claiu or demands that either ..y now or hereafter have
a9ainat the other for support, maintenance or alimony. Husband
and Wlfe further, voluntarily and Intelligently. waive and
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relinquish any riqht to seek from the other any payment for
support, alimony and maintenance and, further, waive and relin-
quish any rights to division of property, other than provided in
this Agreement and, finally, waive any rights to alimony pendente
lite, counsel fees and court costs.
Husband and Wife both aqree that they have been
respectively advised and are aware of the contents of the
provisions of the Oivorce Code, as amended, in Pennsylvania,
wherein considerations are set forth in determining an
appropriate amount, if any, to be paid in the form of alimony.
After being fully advlsed of the contents of the Oivorce Code, as
amended, both parties VOluntarily and intelligently waive and
relinquish any right to seek from the other payaent for support,
aliaony and maintenance.
14. MtmJAL REU'ASE
Subject to the provisions of this Agr....nt, each party
waIve. bls or ber riqht to alimony and further distribution of
property inaaauch as the parties hereto aqree that this Agr....nt
provide. for an equitable distribution of their marital property
in accordance with the Divorce COde, as amended. Subject to the
provlslona of this Agn"Mnt, each party has relmesed and di.-
cbarve4 ud by this Agre...nt does for b1uelf or barulf. and
bia or bar batra. 189al repreaenuUves. e.ltC\ltore,
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administrators and assigns, release and discharge the other of
and from all causes of action, claims, rights or demands what-
soever in law or equity, which either of the parties ever had or
now has against the other, except any or all cause or causes of
action for divorce or except in any or all causes of action for
breach of any provisions of this Agreement. Each party also
waives their right to request marital counseling pursuant to
Section 3302 of the Oivorce Code.
15. SUBSEOUENT OIVORCE
A decree in divorce entered by a court of competent
jurisdiction to either party shall not suspend, supersede or
affect the teras of this Agreement. Both parties agree, if
requested, to enter a Consent Order or Orders concerning the
provisions of this Agreement in the Court of Coaaon Pleas of
CUmberland County, Pennsylvania, or any other Court of competent
juriadictlon, as a part of a resolution of any divorce action
filed or to be filed. This Agree_nt, and the tens and
conditions contained herein, as well as the enforcement of Hid
teras and conditions, shall be contingent upon the grantinq of a
Oivorce Decree to either party by the Court of Common Pleas of
CUmberland COUnty, Pennsylvania, or any other court of coapetent
jurbdlction. Furthenore, both partl.. hereto agree, if
requested, to execute the appropriate .ffldavlts and consents to
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secure a No-fault Oivorce as may be required by the Oivorce Code,
as amended. Both parties agree that this Agreement may be
incorporated into a separate Court Order but shall not merge in
such order.
16. ENTIRE AGREEMENT
This Agreement contains the entire understanding of the
parties and there are no representations, warranties, covenants
or undertakings other than those expressly set forth herein.
Husband and Wife acknowledge and agree that the provisions of
this Agre...nt with respect to the distribution and division of
_rital and separate property are fair, equitable and
satisfactory to them based on the length of their _rriage and
other relevL~t factors which have been taken into consideration
by the parties. aoth parties henby accept the provisions of
this Agreement with respect to the division of property in lieu
of and 1n full and final settle.ent and satisfactlon of all
claiu and deunds that they _y now have or hereafter have
aga1nat the other for equitable distribution of their property by
any court of coapetent jurilldiction pursuant to section J502 of
tM Divorce COde or any aaendMnta thanto. Huaband and VU.
..ch voluntarily and Intelligently valva and relinquish any right
to aeet a ClOIIrt ordehc1 detenlinatlon and dlatributlon of aar1tal
pnptal'ty. but notalt.., '''"In contaiMd tlbaU COUtlt\lte a vatv.r
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by either party of any rights to seek the relief of any court for
the purpose of enforcing 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 their respective
counsel, and each party acknowledges that the Agreement ls fair
and equitable, that it is being entered into voluntarily, with
full knowledge of the assets of both parties, and that it is not
the result of any duress or undue influence. The parties
acknowledge that they have been furnished with all inforlllltion
relating to the financial affairs of the other which has been
requested by each of the. or by their respective counsel.
11. ADDITIONAL INSTRUMENTS
Husband and Wife 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 ..y be reasonably required
to glve full force and effect to the teras of this A9ree..nt.
19. MODIPICATION AND WAIVER
Any aodificatlon or waiver of any of the provlalona of
this Arlre...nt sbal1 be effective only if Mde in writifteJ and
U8C\Jted vlth the sa.. forulity .s this A9re...nt. TIle tailure
of eIther party to lnaist upon strict perforunce of any of the
provlalOM of thla AlIre...nt sball not M conatfU4ld sa a vaivel'
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of any subsequent default of the same or similar nature. The
waiver of any term, condition, clause or provision of this
Agree.ent shall in no way be deemed or construed as a waiver of
any other term, condition, clause or provision of this Agreement.
20. BREACH
If either party hereto breaches any provision of this
Agr...ent, the other party shall have the right, at hi. or her
election, to sue for such breach, or seek other re.edles or
relief a. may be available to him or her. Both parties agree and
are aware that non-compliance with any provision of this Agree-
ment permit. either party to pursue appropriate legal re_dies,
including sanctions as set forth in 23 Pat C.S.A. 13105.
Each party further hereby agrees to save and hold
harmless the other party from any and all attorneys' fees, cost.
and legal expenses and expenses that either may sustain, or incur
or become liable or answerable for, in any way whatsoever, or
shall pay upon, or in consequence of, any default or breach by
the other of any of the teras or provisions of this Agne..nt by
ree.on of which either party shall or shan be obliged to retaln
or 8ftCJAge counsel to Initiete or ..lntain or defend proceedings
again.t the other at lev or equity or both or in any way what-
soever, provided that the party who seeks to recover such
attorneys' f..., coat. and legal eJlP8..... end eJlP8ns.. awat tint
21
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,
b. successful in whole or in part, before th.r. would be any
liability for attorney.' fees, costs, legal expense. and
expen.e.. It Is the specific agreement and intent of the parties
that a breaching or wrongdoing party shall bear the burden and
obligation of any and all costs and expenses and counsel fees
incurred by the other party in endeavoring to protect and enforce
hi. or her rights under thi. Agreement.
All remedies provided by law and all remedies provid.d
for in this Agr....nt for enforcement of the Agreement shall be
deemed to be cumulative and the exercise of one remedy shall not
bar or prev.nt the pursuit of any other remedy and either party
aay elect to pursue .uch remedies simultaneously and the exercise
of a remedy one or more ti... .hall not exhau.t ita use or
prevent further punuit of such remedy.
21. DESCRIPTIVE HEADINGS
The descriptive headings u.ed her.in are for
convenience only. They sban not have any effect Vbataoever in
deteraininq the righta or obUgations of the partIes.
aa. DfDEPEHDEIft' SEPARATE COVENANTS
It is specifically understood and agreed by and betwmen
tM partie. hento that each paralJrapb hereof shall be deeMd to
be a aepante and independent covenant and aqreeaent.
23. AJI.ura.at.. u..
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KIMBERLY S. RI LEY , I IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUM8ERLANO COUNTY, PENNSYLVANIA
I
vs. I CIVIL ACTION - LAW
DANIEL T. RILEY, I 96 - .'f.::J/~ ..."'..:/..:&,"',
Defendant . IN OIVORCE
.
ROTIC! TO D!P!HD AHD CLAIM RIGHTS
You have been sued in Court. If you wish to defend against the
claims set forth 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 in divorce or annulment may be entered against you by
the Court. A judgment may also be entered against you for any other
claia or relief requested in thes. papers by the Plaintiff. You may
lose money or property or other rights important to you, including
custody or visitation with your children.
When the ground for the divorce is indignities or irretrievable
breakdown of the marriage, you may request marriage counseling. A list
of aarriage counselors is available in the Office of the Prothonotary
at the cumberland County Courthouse, CarliSle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, OIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTEO, YOU
MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAD THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TNE OFFICE SET
FORTH BILOW TO FINO OUT WHERE YOU CAN GET LEGAL HELP.
Court Adainistrator
Fourth Floor
cumberland County Courthouse
carlisle, Pennsylvania 17013
(717) 240-6200
(717) 697-0371
By:
raw c. Sheely, Esqu
PAt 1.0. No. 62469
1 West Main Street
Shiraaanatovn, PA 17011
(711) 737-1761
Attorney for Plalntlff
KIMBERLY S. RILEY,
Plaintiff
.
.
.
.
.
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLANO COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
96 - ~'.JI.l. (:.,..i 7..-.
IN OIVORCE
vs.
.
.
:
DANIEL T. RILEY,
.
.
Defendant
.
.
COIIPLatll'r
comrr I - DIVORCB
1. Plaintiff is Kimberly S. Riley, who currently resides at 429
West Kain Street, 2nd Floor Apt., Mechanicsburg, CulIIberland County,
Pennsylvania.
2. Defendant is Daniel T. Riley, who currently resides at 20
Fluil'lCJO Court, P.O. Box 854, Kantauk, N_ York.
3. PlaintIff has been a resident of the Commonwealth of Pennlyl-
vania for at least six (6) months t.aediately previous to the filing of
thia COIlPla1nt.
4. Plaintiff and Defendant _re _rried on october 14, 1989, at
hat Hallpton, "_ York.
S. Tbere have been no prior actions of divorce or annul..nt
between the partie..
6. PlaIntiff ba. been edvised of the avaUability of _rrlaqe
counaeUft9 and \&nderetanda that aha uy bave tM r19ht to request that
the court req\llre tM parties hereto to particIpate in counsellnq.
.,. 'laint.iff Avera .. tM Vround. upon which this action 1. baaed
ia thata
(A) That the marriage between the parties hereto is
irretrievably broken and that the Plaintiff and Oefendant have lived
separate and apart since August 28, 1995 or, in the alternative;
(8) That Plaintiff and Defendant are now living separate and
apart and, at the appropriate time, Plaintiff will submit an Affidavit
alleging that the parties have lived separate and apart for at least
two (2) years and that the marriage is irretrievably broken.
WHEREFORE, Plaintiff requests Your Honorable Court to enter a
decree in divorce divorcing Plaintiff and Defendant absolutely.
comrr II - CUSTODY
8. Paragraphs 1-1 are hereby incorporated by reference as if set
forth at length.
9. The parties are the natural parents of Cameron H. Riley, born
April 3, 1992.
10. Plaintiff and the mlnor chlld have been residents of the
Coaaonvealtb of Pennsylvanla for at least six (6) months prior to this
proceeding.
11. The minor child currently resides with Plalntiff and has
periods of t8llPQrary physical custody with Defendant in acconlance with
a CUstody Agreement dated October 3, 1995.
12. Plaintiff i. not aware of any other persons who would have
claim to custody of ..1d minor child.
2
13. It would be in the best interest of the child to have an
Order of court entered setting forth primary physical custody awarded
to Plaintiff.
14. Plaintiff believes that the parties will be willing to enter
into an agreement concerning custody wherein the prior agreement dated
October 3, 1995 would be generally incorporated into an Order of Court.
WHEREAS, Plaintiff hereby requests that Your Honorable Court enter
an Order of Court addressing issues of legal custody and awarding
Plaintiff primary physical custody of the child, with right of partial
custody reserved for Defendant.
Respectfully submitted
Date:
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Andrew C. Sheely, tsquire
Attorney for Plaintiff
(SEAL)
ftRIPICA'I'IOH
I verify that the stat.ments made in this Complaint are true and
correct. I understand that false statements herein are made subject to
penalties of 11 Pa.C.S.A. Section 4904, relating to unsworn falsifica-
tion to autborlti...
Date: <;Y~'I"",h~~
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KIM8ERLY S. RILEY,
Plaintiff
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
96 _ ~;;'I;L 6.~'<.i UL_
IN OIVORcE
vs.
DANIEL T. RILEY,
Defendant
DFIDAVI'l'
Kimberly s. Riley, being duly sworn according to law, deposes
and says:
(1) I have been advised of the availability of marriage
counseling and understand that I may request that the Court require
that my spouse and I participate in counseling.
(2) I understand that the Court maintains a list of marriage
counselors in the Domestic Relations Office, which list is available to
me upon request.
(3) Being so advised, I do not request that the Court
require that my spouse and I participate in counseling prior to a
Oivorce Decree being handed down by the Court.
I understand that false statements herein are made subject to
the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsi-
fication to authorIties.
,
KI~~~~C~~~ e'tj
SWORN to and subscribed before
me this ,N" day of ,"'.":''l;",t(oi' I , 1996.
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KIMBERLY S. RILEY, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff . CUMBERLANO COUNTY, PENNSYLVANIA
.
:
VB. . CIVIL ACTION - LAW
.
.
.
OANIEL T. RILEY, : 96 - 5212
Defendant . IN OIVORCE
.
Al'I'IDAVIT OF CONSBNT
1. A Complaint in Oivorce under Section 3301(c) of the
Oivorce Code was filed on September 20, 1996.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing the
Complaint.
3. I consent to the entry of a final decree of divorce after
service of notice of intention to request entry of the decree.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to
unsworn falsification to the authorities.
DATE:
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KIMBERLY S. RILEY, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs. . CIVIL ACTION - LAW
.
.
.
DANIEL T. RILEY, . 96 5212
.
Defendant . IN DIVORCE
.
DIVER OJ' NOTICE OJ' INTENTION TO REQUEST
ENTRY OJ' A DIVORCB DECREE UNDER
13301 (0) OJ' THE DIVORCE CODE
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 do not claim them
before a divorce decree 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 are true
and correct. I understand that false state.ents herein are made
subject to the penaltles of 18 Pa.C.S.A. Section 4904 relating to
unsworn falsification to the authorities.
DATlt_l- ~'J' (1'1
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KIKBIIU..Y S.
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KIMBERLY S. RILEY, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff . CUMBERLANO COUNTY, PENNSYLVANIA
.
.
.
vs. . CIVIL ACTION - LAW
.
.
.
DANIEL T. RILEY, . 96 5212
.
Defendant . IN OIVORCE
.
WAIVBR or HO'l'ICE or INTBNTION TO DQUZ8T
D1TRY or A DIVORCE DECJUlE UllDER
13301 (0) or THB DIVORCE CODE
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 do not claim them
before a divorce decree is granted.
3. I undentand that I will not be divorced until a divorce
decree is entered by the COurt and that a copy of the decree wUl be
sent to .. l-.diately after it is fUed with the prothonotary.
I verify that the statements ..de in this Affidavit are true
and correct. I understand that tal.. statements herein are _de
subject to the penaltie. of 18 Pa.C.S.A. SecUon 4904 relaUnq to
DATIl January 2. 1991
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unavorn falsification to the
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KIMBERLY S. RILEY, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff . CUMBERLANO COUNTY, PENNSYLVANIA
.
.
.
vs. . CIVIL ACTION - LAW
.
.
.
DANIEL T. RILEY, . NO. 96 5212
.
Defendant . IN OIVORCE
.
Al'I'IDAVIT 01' 8J1RVIIIQ COMPLAIII'1'
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLANO
.
.
: 55.
.
.
ANDREW C. SHEELY, being duly sworn according to law deposes and
says that he caused the Complaint in the above-captIoned matter to be
served by Certified Mail, Restricted Delivery, Return Receipt
Requested, as indicated by the attached receipt cards.
SWORK to and aubacribed before ..
this .,'fU' day of .)~.'d ,1 'I , 19'7.
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KIMBERLY S. RI LEY , . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff . CUMBERLANO COUNTY, PENNSYLVANIA
.
.
.
VS. . CIVIL ACTION - LAW
.
.
.
OANIEL T. RILEY, . 96 - 5212
.
Osfendant . IN OIVORCE
.
CUSTODY STIPULATION AHD AGRBBKENT
THIS AGREEMENT ANO STIPULATION entered into this Z'It'- day of _
....-.-
::J a.-t.-,~ ' 1997, by and between Kimberly S. Riley (hereinafter
referred to as "MotherM) and Daniel T. Riley (hereinafter referred to
as
"Father").
WHEREAS, the partie. are the natural parents of Cameron Hunter
Riley, 0.0.8., April 3, 1992, and
WHEREAS, Mother is the natural mother of the aforenaaed child and
rather i. the natural father of the aforenaaed Child, and
WHEREAS, the partie. live in separate residence. and different
Stat.., and
WHERIAS, the partl88 wlah to enter into an Agreement and StipUla-
tion relative to custody and partlal custody of the child: and
NOW, 'lHIJUtPOU. In consideration of the mutu.tll covenants, proaia..
(1) Mother and Father shall have shared legal custody of the
child, meaning that both parents shall make joint decisions concerning
the child's education, serious medical decisions affecting the child
and religious instruction: and
(2) Mother shall have primary physical custody of the child: and
(3) Mother and Father agree that Father shall have periods of pa-
rtial physical custody on the following basis:
(a) On every third (3rd) weekend, commencing at 9:00 p.m. on
Friday, and continuing through Sunday evening at 6:00 p.m.: and
(b) On an alternating Holiday basis, commencing with Thanksg-
iving in 1996. For purposes of this Agreement, Holidays shall be
defined as Thanksgiving Day, Christmas Day, New Years Day, Easter
Holiday, Memorial Day, Fourth of July and Labor oay. In the event
a Holiday falls on a Friday or Monday prior to or following the
alternating custody period, such custody period shall be adjusted
to allow for a longer custody period in accordance with the
alternating custody period: and
(c) In the event an alternating custody period would occur on
a holiday, the parties agree that the alternating custody period
shall be modified to conform with holiday contact period as set
forth above.
(d) Father shall have thirty (30) days of temporary, partial
custody as a summer vacation with the child. A period of partial
custody within the thirty days shall not exceed fourteen (14)
days. In the event Father desires partial custody with the child
as a sua.er vacation, he shall provide Mother with notice of such
intention within thlrty (30) days of the requested time period and
subalt such notice to Mother prior to June 1 of the appropriate
year. rather shall re..in responslble for all expenses incurred
bI the child during his su...r vacation and shall provide Mother
v th all telephone number. where the child can be reached during
such period.
(e) In additlon to the dates and tl... set forth above, the
chlld MY .pend Mother's Day with Mother and rather's Day wlth
rather. f convenient and aqneabie to both partie..
2
(f) And any other times as the parties may agree.
(4) All pick-ups and drop-offs involving the child shall occur at
a mutually agreed upon location in Fort Lee, New Jersey, or any other
location as agreed upon by the parties.
(5) The parties will keep each other immediately advised to any
emergencies concerning the child and shall further take any necessary
steps to insure that the health and well being of the child is always
protected. The parties shall provide each other with all home and work
telephone numbers, as well as current addresses for the residence of
the child. Both parties further agree to allow each other to speak with
the child at any and all reasonable times as set forth below.
(6) Neither parent shall do anything which may estrange the child
from the other party, or Injure the opinion of the child as to the
other party, or which may hamper the free and natural development of
the child's love or affection for the other party.
(7) Mother and rather agree that each shall communicate to each
other through one-another whenever posslble in accordance with the
teras set forth in this Agreement and that they shall avoid using child
as a liaison to coaaunlcate with each other a. to oral aodlfications of
this Agreement.
(I) Mother and Father agree that there shall be reasonable teleph-
one acce.. between the child and the non-custodlal parent. Ttle partie.
:s
. .
agree to endeavor to place telephone calls to the child between 7:00
and 9:00 p.m., so as not to interfere with dinner or bedtime.
(9) Should Father predecease the child, Mother shall be entitled
to sole legal and physical custody of the child without interference
from Husband'. family or friends in accordance with applicable law,
Should Mother predecease the child, Mother shall be entitled to sole
legal and physical custody of the child without interference from
Husband's family or friends in accordance with applicable law.
(10) In the event Father or Mother relocate to a new location
during the term of this Agreement, the relocatinq party shall provide
thirty (30) days notice of the decision of the notice. Upon receipt of
.uch notice, the parties shall mutually discuss an agreed upon pick-up
and delivery location, if possible, and any modifications to this
CUstody Agreement shall be discussed at such time,
(11) The parties agree that the within Agreement shall be reduced
to an Order of Court and that either party may petition any Court with
appropriate jurisdiction over the child should circuastances change and
modification is nece.s.ry.
WITNUS: )'rJ
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
v.
)
)
)
)
)
)
)
NO. 96-52 I 2
KIMBERLY S. RILEY,
Plaintifl7Respondent
DANIEL T. RILEY,
DefendantlPetitioner
CIVIL ACTION - LAW
DIVORCE/CUSTODY
ORDER OF COURT
AND NOW, \'Illi' i'l 1'-1'1(1 .1999,uponconsiderationoftheattached
petition, it is hereby directed that the parties and their respective counsel appear before
(r"l'lll1o'l L l'IIIlQs"Esquire,theconciliator.at '3M ), ISTl<<.t r'(\/lIi~ tlli l.l'
PetU1Sylvania,on the I.~'r <lay of J,jj I ,1999.at >')) ~[(
o'clock L.m. for a Pre-Hearing Custody Conference. At suCh conference. an effort will be
made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the
issues to be heard by the court. and to enter into a temporary order. Either party may bring the
child who is the subject of this custody action to the conference, but the child's attendance is not
mandatory. Failun: to appear at the conference may pro\1de grounds for entry of a temporary or
permanent order.
FOR THE COURT.
By: ,Ji,'llff( /.
Custody Conciliator
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YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR
TELEPHONE mE OFFICE SET FORni BELOW TO fiND OUT WHERE
YOU CAN GET LEGAL HELP.
~ERICA.""S \\1TH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is .red by law to comply with the
Amerians with Disabilities Act of \990. For information *ul accessible facilities and
~Ic IICC:OIIImOdati a\"aiWlle to disabled indi\iduaIs bavillJ business before the court.
pkue COfttaCl 0IlI' ofl1cc. All amngcmcnts must be made ..Icast 72 hours prior to any harin.
Of businat before the court. 'I' au must attend the sdlCdvlol tol\ferenc:t or harina.
Cumbertand County Bar Association
2 Uberty A\'UNC
Carlisk.PA 11013
Te:\qlholIe: (717) 2~~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KIMBERLY S. RILEY,
Plainti/TlRespondent
v.
)
)
)
)
)
)
)
NO. 96-5212
DANIEL T. RILEY.
Defendant/Petitioner
CIVIL ACTION . LAW
DIVORCE/CUSTODY
PETITION TO MODIFY ORDER OF CUSTODY
Defendant Daniel T. Riley, by and through his counsel. Howett. Kissinger & Miles. P.C,.
hereby files this Petition to Modify Order of Custody and in support thereof avers as follows:
1. Petitioner is Daniel T. Riley (hereinafter refemd to as "Father").
defendant in the above-captioned divorce and custody action. who resides at 20 Flamingo Court,
Montauk, New York, 11954.
2. Respondent is Kimberly S. Riley (heRinafter referred to IS "Mother").
plaintifTin the above-c:aptioned divorce and custody action. who currently resides at 429 West
Main Street, Mcchanicsbura. Cumberland County, Pamylvania. 17055.
3. The parties were formerly husband and ."ifc. havilll been married on
October 14. 1989 and divorced by decree oftbis Court entcmi on FebnIary 7. 1997.
4. The parties are tbe natural parents of one minor child: CamcrtlIl H\IIltcr
Riley. born ApriI3. 1992.
S. Tbcft ..........dy is in clTect . custody order dated FebnIary 3. 1997. Wb..~
at tbe Ibo~ lam ... numtIa by tbe IlMolablc Edpr B. 8&yky. Aid order 11m", been CIlICnd
by mpo,alatioa....... L _ ortbe pdcs. A tnW'" (Oftfd tOpy or. F...,.). 1991
order is ....M-' hmto u E.Ulibd -A..... is iftoolpoeltled haea by rcL.....e f ...
(3) Easter - In 2000 and in all even-numbered
years thereafter, from 9:00 p.m. on the Friday
of Easter weekend until 5:30 p.m. on Easter
Sunday. Mother shall have custody of Cameron
on Easter weekend in odd-numbered years.
C. Summer schedule - Father shall have the child for
eight 18) weeks which may be consecutive during the
summer months. He shall notify Mother within sixty
(60) days of the summer as to when he intends to
exercise these periods of exclusive custody.
Mother shall always have the first week of July or
thereabouts which shall coincide with her annual
trip to the beach. Mother shall notify Father
within thirty 130) days as to when she intends to
exercise that period of tune with the child.
Father shall be entitled to iii make-up week should
that week be in the middle of his eight (8) weeks
of summer time with the Child.
In the Event that C.-ron is with rather
dUrlnq the summer for a period of s1x (6)
cOM~t1'1e ItEitk$ or lCllger. Mot~,fU shall ~
entitled to visit with the child fOf un. of tho!.
'-
and correct copies of the invoices for the unreimbursed medical expenses due and owing are attached
hereto and incorporated herein as Exhibit.S".
8. The Respondent was notified by the Petitioner that, pursuant to section 12(A)(iii) of the
Agreement he is responsible for all of the school and sports-related extracurricular expenses incurred by
Cameron, including expenses for summer camp. sports equipment and photographs, totaling $350.48. True
and correct copies of the invoices for the extracurricular activity expenses due and owing are attached
hereto and incorporated herein as Exhibit.C".
9. Since April 1, 2004 the Respondent has failed to make the current $705.97 full amount due
and owing for child support by making 5 payments for the period from March 1, 2OO4lhrough July 1, 2004 in
the amount of $700.00, thereby making the ReSpondent $29.85 in arrears for that time perioct
10. The Respondent has failed to pay his required August 1. 2004 child support payment. half of
the unreimbursed medical expenses In the amount of $158.00, for any of Cameron's extracurrlcular activities
totaling $350.48, and has failed to make payments In full for the March 1,2004 through July 1,2004 period
and therefore, is obligated to pay One Thousand Two Hundred Forty-Four Dollars and 301100 ($1.244.30)
pursuant to the Agreement
11, The Agreement fur1her states in paragraph 20:
20. BREACH
If either party hereto breec.hes any provision of this Agreement, the other
party IhaII have the right. at his or haf election, to sue for such breach, or seek
other ntmIdles or relief IS may be available to him or haf. BoCh parties agree
end 11'I aware that IlOlHXlmpIiance with any provision of this Aoreement permits
either party to pursue appropriate legal remedies. induding SItldiDI\t IS lit for1h
in 23 Pa. C.SA f310Lh Is the spedlic agreement and intent at the pnes that
a breaching or wrol agdoing party IhaII bear the burden end obligation at any and
aI COlts and expenIII and COUI'lIIl fHl inc:umId by the other party in
ende8wring to protec;l and ..!bee his or haf rigIltI under this AQrMmet It
'2. The IblOfable K4Mn A. Hess has ~ ruled on other isIUIS in IhiI case,
m~ lhe rllill~l* ~ ~ htltlil.4onoratlIlt COlI1..-", 0RtIr:
A. F"nIing ... RIISlolllden. in tnad\ at fit pert..' ~tallll P"~"~ Iftd Ir\lunlnt
Aglllllle.'lt;
...... A
MARITAL PROPERTY AND SETTLEMENT AGREEMENT
I
., 'I""
THIS AGREEMENT, made this ~ day of January, 1997, by
and between Kimberly S. Riley, party of the first part, hereina-
fter referred to as "Wife", and Daniel T. Riley, party of the
second part, hereinafter referred to as "Husband".
WITNESSETH:
WHEREAS, the parties hereto are husband and wife,
having been married on October 14, 1989 in East Hampton, Long
Island, New York, separating on August 28, 1995; and
WHEREAS, there has been a child born of the parties
during marriage, namely Cameron Hunter Riley, 0.0.5. 04/03/92,
hereinafter referred to as "child"; and
WHEREAS, certain differences have arisen by and between
the parties as a result of which they have now separated, living
independent and apart from one another, and the parties hereto
are desirous of settling fully and finally their respective
financial and property rights and obligations as between each
other including, without limitation by specification: the
settling of all matters between them relating to the ownership
and equitable distribution of real and personal property; the
.ettlinq of all matters between them relating to the past,
present and future support and/or maintenance of the child: the
impl...ntation of custody/visitation arranqe=ents for the minor
child of the parties: the settlinq of all matters between th..
relating to the past, present and future support, alimony and/or
maintenance of Wife by Husband or of Husband by Wife; and in
general, the settling of any and all claims and possible claims
by one against the other or against their respective estates.
WHEREAS, the parties being fully advised as to their
respective rights, duties and obligations growing out of their
marital status, particularly with respect to the relevant sec-
tions of the Divorce code, Act of April 2, 1980, P.L. 63, Act No.
26, as amended, 23 P.S. 3101 at sea., and being fully aware of
their right to consult with or having consulted with their
respective legal counselor advisors, namely Andrew C. Sheely,
Esquire, Attorney for wife, and Husband, pro se, being fully so
advised consult with an attorney, and acknowledging the oppo-
rtunity and ability to request a full and complete disclosure of
income and assets from the other, and reviewing this Agre..ent,
have com. to an agreement as to each and all of their said
matters of property and relations: and
WHEREAS, Wife has filed a Complaint in Oivorce, said
complaint beil\9 docketed in the Prothonotary'. office of Cuaber-
land county, Pennsylvania, at No. 96 - 5212.
MOW, THEREFORE, in consideration of the abOve recitals
and the .utual connanta hereinafter set forth, each of the
parti.. hereto lntendinq to be legally bound hereby by aUix1ft9
:2
their hands and seals agree as follows:
1. ADVICE OF COUNSEL
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 effect in advance of
the date set forth above to permit such independent review. Each
party acknowledges that he or she has had the opportunity to
receive independent legal advice from counsel from his or her
selection, and that each fully understands the facts and has been
fully informed as to his her or her legal rights and obligations,
and each party acknowledges and accepts that this Agreement is,
and the circumstances, fair and equitable, after having the
opportunity to receive such advice and with such knowledge, and
that execution of this Agreement is not the result of any im-
proper or illegal agreement or agreements. In addition, each
party hereto acknowledges that he or .he has had the opportunity
to be tully advised by his or her respective attorney of the
illpact of the Pennsylvania Oivorce Code, whereby the court has
the right and duty to determine all marital rights of the parties
includinq divorce, aliaony, aliaony pendente lite, equitable
cSi.tribution ot all aar1 tal property or property owned or pos-
....ed individually by the other. counsel f.es and costa of
lltlqation and. fully knowlnq the .... and having the opportunity
3
to be fully advised if his or her rights thereunder, each party
hereto still desires to execute this Agreement, acknowledging
that the terms and conditions set forth therein are fair, just
and equitable to each of the parties, and waives his and her
respective right to have the Court of Common Pleas of Cumberland
County, or any other court of competent jurisdiction, make any
determination or order effecting the respective parties rights to
a divorce, alimony, alimony pendente lite, equitable distribution
of all marital property, counsel fees and costs of litigation.
2. SEPARATION
It shall be lawful for each party at all times
hereafter to live separate and apart from each other in such
place or places as he or she may from time to time choose.
3. INTERFERENCE
Each party shall be free from interference, authority
and control, direct or indirect, by the other as fully as if he
or she were single and unmarried. Neither shall molest the other
or their respective families, or compel or endeavor to compel the
other to cohabitate or dwell with him or her, or to in any way
harass or malign the other or their respective families.
4. WAIVER or CLAIMS AGAINST ESTATES
Except as otherwise prOVided herein, Husband relin-
quishes his inchoate intestate right and his right to act as a
4
personal representative in the estate of Wife, and Wife relin-
quishes her inchoate intestate right and her right to act as a
personal representative in the estate of Husband. Each of the
parties hereto by their presents, for himself or herself, his or
her heirs, executors, administrators or assigns, does remise,
release, quit-claim and forever discharge the other party hereto,
his or her heirs, executors, administrators or assigns or any of
them, of any and all claims, demands, damages, actions, causes of
actions, suits, at law or equity, of whatsoever kind or nature,
for or because of any matter or thing omitted or suffered to be
done by said other party prior to and including the date hereof,
except that this release shall in no way exonerate or discharge
either party hereto from the obligations and promises made and
imposed by reason of this Agreement and shall in no way affect
any cause of action in absolute divorce which either party may
have against each other.
5. MARITAL PROPERTY
The parties hereto acknowledge that during their
marriaga they have acquired, individ~ally or jointly, various
assets and property, including miscellaneous bank accounts,
personal property, construction tools and equip.ent, motor
vehicles, computers, electronic equipment, quns. archery equip-
..nt, other sporting goods and other aiscallan.cus liabilities
5
and credit card debt.
Husband and Wife acknowledge that they are aware of
their respective rights pursuant to the Oivorce Code of 1980, as
amended, to obtain formal valuations or appraisals of the marital
residence, and other items of marital property. The parties
hereby waive any necessity for completing or attaching any
financial disclosure(s). Each party further acknowledges the
opportunity to attach a full and complete financial disclosure
and that such disclosure is not desired to effectuate a fair and
equitable resolution of their marital rights, duties and obliga-
tions as provided in the Divorce Code of 1980, as amended.
6. PERSONAL PROPERTY
The parties hereto mutually agree that they have
effected a satisfactory division of the furniture, household
furnishings, appliances and other household personal property
between them, and they mutually agree that each party shall from
and after the date hereof be the sole and separate owner of all
such tangible personal property presently in his or her posses-
sion, Whether said property is heretofore owned jointly or
individually by the parties her.to, and this Agr...ent shall have
the effect of an assiqnaent or bill of aal. fro. .ach party to
the other for such property as llIay be in the incUvidual posses-
sions of each of the parties h.r.to.
6
7. MOTOR VEHICLES
The parties hereto agree that Husband shall be entitled
to have the sole and exclusive control, benefit, use and title of
the 1989 Ford 150 Van, or the proceeds thereof, and that he shall
further hold Wife harmless from and assume full responsibility
for any liability for the 1989 Ford 150 Van. The parties hereto
agree that wife shall be entitled to have sole and exclusive
control, benefit, use and title of the 1992 Toyota Corolla, or
the proceeds thereof, and that she shall hold Husband harmless
from and assume full responsibility for car payments to the
Suffolk National Bank, insurances and liability for such motor
vehicle.
The parties hereto agree that titles to the motor
vehicles shall be transferred within thirty (30) days from the
date of this Agreement to the party receiving title, if
applicable.
8. MISCEU ANEOUS
(A) The parties hereto acknowledge and agree that any
and all savings and checking accounts. as well as certificates of
deposit and other investment accounts, owned by the. jointly or
singly, have been divided to their autual and individual satis-
faction.
7
(B) Neither party hereto shall make a claim upon the
other for accumulated pension, profit-sharing, retirement sup-
port, retirement benefits, insurance policies, IRA's, or any
retirement-related benefits, excepting only those benefits set
forth in the Agreement.
(e) The parties hereto acknowledge and agree that any
and all life insurance policies owned by them jointly or singly
have been divided to their mutual and individual satisfaction.
Each party hereto acknowledges that they have in their sole
possession those policy or policies of life insurance which they
intend to keep and retain as their sole and exclusive property
and, further, each party shall have the right to designate the
beneficiaries of said policies.
(D) The division of existing marital property is not,
except as otherwise expressly provided herein, intended by the
parties to constitute in any w~y, a sale or exchange of assets
and the division is being affected without the introduction of
outside funds or other property not constituting a part of the
marital estate. As a part of an equitable division of the
marital properties and the marital settlement herein contained,
the parti.s hereto agree to save and hold each other harales.
froa all income taxes assessed against the other resulting from
the division of the property as herein provided.
.
(E) Each party represents and warrants to the other
that he or she has not incurred any debt, obligation or other
liability, other than those described in this Agreement, on which
the other party is or may be liable. A liability not disclosed
in this Agreement will be the sole responsibility of the party
who has incurred or may hereafter incur it, and such party agrees
to pay it as the same shall become due, and to indemnify and hold
the other party and his or her property harmless from any and all
such debts, obligations and liabilities.
(F) Each party represents and warrants to the other
that each shall file separate income tax returns for tax year
1996 and thereafter. Information maintained by one party which
is necessary to complete any subsequent income tax return by the
other party shall not be unreasonably withheld upon the request
of either party.
10. DEBTS OF HUSBAND AND WlFE
Husband and Wife acknowledge that they have incurred
various marital, (joint and separate) debts prior to separation.
At the date of separation, Husband and Wife were indebted to the
following .ntiti.. in the following approximate amounts:
lAM Amount of Debt
A. citibank visa n,ooo.OO
I. Uneaployaent Insurance Division $2,700.00
9
Wife represents and warrants to Husband that from the
signing of this Agreement and in the future Wife will pay for
such debts and assume full responsibility for such debts in
accordance with this paragraph. Husband agrees that he shall pay
Wife a total amount of $750.00 to apply to such debts, at the
minimum rate of $125.00 a month until such debt in the amount of
$750.00 is fully satisfied. Upon payment of the amount of
$750.00, Wife shall hold Husband harmless from any and all claims
or demands made against her by reason of such debts. Payment of
the sum of $750.00 from Husband to Wife shall occur prior to May
1, 1997.
The parties hereto agree that any and all obligations
incurred subsequent to the date of separation, said date being
August 28, 1995, shall be the sole and individual responsibility
of the party incurring the obligation.
Husband represents and warrants to Wife that from the
signing of this Agreement and in the future he will not contract
or incur any debt or liability for which Wife or her estate might
be responsible and shall indemnify and save harmless Wife frea
any and all claims or demands made against her by reason of debt.
or obligations incurred by hi..
Wife represents and warrants to Husband that froa the
signing of this Agreement and in the future she will not contract
10
~
or incur any debt or liability for which Husband or his estate
might be responsible and shall indemnify and save harmless
Husband from any and all claims or demands made against him by
reason of debts or obligations incurred by her.
11. CUSTODY.
Husband and Wife acknowledge that a prior Agreement
dated October 5, 1995 has provided the parties with a general
custody schedule for approximately one year. It is the specific
intent of Husband and Wife to modify the terms of the prior
custody agreement to reflect the present custody arrangement
which has been changed due to transportation and traveling
concerns between the State of New York and the Commonwealth of
Pennsylvania. Husband and wife acknowledge that they have modif-
ied the prior Agreement dated October 5, 1995, and desire that
the provisions of this paragraph supersede any prior Order of
Court or agreement of the parties, as follows:
(A) Mother and Father shall have shared legal custody
of the child, meaning that both parents shall =ake joint
decisions concerning the child's education, serious medical
decisions affecting the child and religious instruction: and
(8) Mother shall have primary physical custody of
the child: and
11
.
(e) Mother and Father agree that Father shall have
periods of partial physical custody on the following basis:
(i) On every third (3rd) weekend, commencing at
9:00 p.m. on Friday, and continuing through Sunday
evening at 6:00 p.m.; and
-
~
(ii) On an alternating Holiday basis, commencing
with Thanksgiving in 1996. For purposes of this
Agreement, Holidays shall be defined as Thanksgiving
Day, ~hristmas Day, New_Years pay, Easter Holiday, -
MelUorlarJ~ay-;- Fourth of .J.ul;L...And l,.al)or -bay.':. In the
event a Holiday falls on aYtiday or Monday~prior to or
following the alternating custcidy..periOa; such custody
period shall be adjusted to allow for a lo~g!r_~~~tody
period in accordance with the alternating custody
perToa: and
, (iii) In the event an alternating custody period
,'would occur on a holtdav, the parties agree that the
'f ~.alternating custoay period shall be modified to conform
:;.IY., l with holid~LSQEj:act peric:d as set forth above.
(iv) Father shall have thirty (30) days of tem-
porary, partial custody as a summer vacation with the
child. A period of partial custody within the thirty
days shall not exceed fourteen (14) days. In the event
Father desires partial custody with the child as a
summer vacation, he shall prOVide Mother with notice of
such intention within thirty (30) days of the requested
time period and submit such notice to Mother prior to
June 1 of th, ~ppropriate year. Father shall remain
responsible for all expenses incurred by the child
during his summer vacation and shall provide Mother
with all telephone numbers .here the child can be
reached during such period.
((y~' In addition to the date. and time. set forth
above, the child may spend Mother's Day with Mother and
Father's Day with Father. if con~enient and agreeable
to both parties. - .-',
(vi) And any other times .. the partie. may agr...
(D) All pick-ups and drop-Off. involving the child
12
shall occur at a mutually agreed upon location in Fort Lee,
New Jersey, or any other location agreed upon by the par-
ties.
(E) The parties will keep each other immediately
advised to any emergencies concerning the child and shall
further take any necessary steps to insure that the health
and well being of the child is always protected. The parties
shall provide each other with all home and work telephone
numbers, as well as current addresses for the residence of
the child. Both parties further agree to allow each other to
speak with the child at any and all reasonable times as set
forth below.
(F) Neither parent shall do anything which may estrange
the child from the other party, or injure the opinion of the
child as to the other party, or which may hamper the free
and n4tural dev.lopment of the child'. love or aff.ction for
the other party.
(G) Mother and rather a'ln. that each shall COIlllunicate
to ..ch other through one-another When.v.r possible in
accordance with the term. .et forth in this A9r...ent and to
avoid \Uling child .. . liaison to cOlll'lllunieat. with each
other aa to oral aodificatlona of this Agre...nt.
.
13
(H) Mother and Father agree that there shall be reason-
able telephone access between the child and the non-cus-
todial parent. The parties agree to endeavor to place
telephone calls to the child between 7:00 and 9:00 p.m., so
as not to interfere with dinner or bedtime.
(I) Should Father predecease the child, Mother shall be
entitled to sole legal and physical custody of the child
without interference from Husband's family or friends in
accordance
with applicable law.
t~~,.,..(
Met.l...l;; shall be entitled to
Should Mother predecease
{/ :~'the child,
L .',. .
~::_~.~~1.~ical custody of the child without interference from
~~ family or friends in accordance with applicable
sole legal and
law.
(J) Xn the event Father or Mother relocate to a new
location during the term of this Aqreement, the relocating
party shall provide thirty (30) days notice of the decision
of the notice. Upon receipt of such notic., the parti..
shall .utually discuss an agreed upon pick-up and delivery
location, if possible. and any modifications to this CUstody
Aqr....nt shall be discussed at such time.
(X) the partie. aqr.. that the within Agreement shall
be reduced to an Order of Court and that either party _y
petition any Court with appropriate jurisdiction over the
14
child should circumstances change and either party desire
modification of this Agreement.
12. SUPPORT FOR eHILD
A. child SUDDort Husband and Wife acknowledge that a
prior Agreement dated October 5, 1995 has provided the parties
with a general child support payment schedule for approximately
(1) one year. It is the specific intent of Husband and Wife to
modify the terms of the prior child support payment agreement to
reflect the present financial interests of the parties. Husband
and Wife acknowledge that they have modified the prior Agreement
dated October 5, 1995, and desire that the provisions of this
section supersede any prior Order of Court or agreement of the
parties, as follows:
(i) Husband acknowledges that he shall pay child
support in the amount of $800.00 per month, commencing on
November 1, 1996, payable to Wife for the benefit of the
ainor child. All payments are due on the first day of each
month and in no circumstance shall payments be later than
the tenth (lOth) day of each month. In the event payments
are late, Wife shall have the option to petition for child
IUpport in accordance with subparagraph B as indicated below
and require that any child support enforcement agency
a4ainister the proviSions of this Agreement or any lubse-
IS
quent modifications thereto, with the costs of such enforce-
ment to be paid for by Husband.
(ii) Husband shall continue to pay child support in the
amount of $800.00 per month until April 1, 1997, when the
amount of child support shall decrease to an amount of
$575.00 per month. Commencing on April 1, 1998, an annual
,....... ......
cost of living adjustment equal to two and one-half percent
(2.5\) shall be added to the payment of child support of
$575.00 or any additional amount agreed upon thereafter.
_.._-~_.-.
(iii) Husband shall pay for any and all reasonable
school and sports related extracurricular expenses incurred
by eameron, including expenses for uniforms, sports gear,
shoes, equipment.
(iv) Husband and Wife agree and acknowledge that these
amounts are presently sufficient for child support and day
care expenses associated with the proper support and main-
tenance of the minor child. Child support shall continue
through the child's graduation from hiqh school or e~cipa-
tion, whichever occurs first.
(v) Wife shall maintain the child'. health insurance,
provided she is able to obtain such health insurance bene-
tits for the child at a reasonable cost. In the event any
health or aedical expen... ere not paid by Wits'. insurance,
16
Husband and Wife agree to share equally any unreimbursed
medical or health expenses incurred by the child.
B. Modification of child SUDPort
Notwithstanding the terms of this Section and this Agree-
ment, Husband and Wife understand that circumstances may neces-
sitate an adjustment in the amount of support either upwards or
downwards, depending upon the child's circumstances and the
respective incomes or earning capacities of the parties hereto in
accordance with general support standards. In the event Husband
and Wife cannot agree upon the amount of child support at any
time hereafter, Husband and Wife agree that nothing set forth in
this paragraph or this Marital Property and Settlement Agreement
shall prejudice the right of either party to file a petition for
modification of the amount of child support, at any time, in any
Court of appropriate jurisdiction, if necessary. It is the
specific intent of the parties that this Agreement is designed to
avoid the present filing of formal child support proceedings
only, and any future award of child support will be governed by
the applicable support quidelines and case law.
However, in the event of remarriage, the income of the
spouse of Wife or Husband shall not be directly consl~ered in
deteraining any child support award, and it is the intention of
Husband and Wife that their respective ineoaes or earning capaei-
11
ties shall be the primary consideration in determining a child
support payment.
e. Colleae Suooort
Although no binding provisions are set forth in this
Marital Property and Settlement Agreement to require payment for
the child's college support, Husband and Wife recognize that a
college support obligation could exist in the future. While
Husband and Wife recognize such potential responsibility, no
provisions requiring either party to pay for college support are
set forth in the Marital Property and Settlement Agreement due to
the status of the law in Pennsylvania and to the variety of cir-
cumstances which could arise in the future. Nonetheless, Husband
and Wife acknowledge that either party may contribute to the
child's college support in the future and/or set up college funds
for such potential future obligation for the child's benefit.
13. ALIMONY. SUPPORT AND MAlNTtNANCE
Both parties acknowledge and agree that the provisions
of this Agreement providing for equitable distribution of marital
property are fair, adequate and satisfactory to them and are
accepted by the. in lieu of and in full and final satisfaction of
any clai.. or deaands that either may now or hereafter have
against the other for support, maintenance or aliaony. Kuaband
and Wife further, volun~arily and intelligently, waive and
11
relinquish any right to seek from the other any payment for
support, alimony and maintenance and, further, waive and relin-
quish any rights to division of property, other than provided in
this Agreement and, finally, waive any rights to alimony pendente
lite, counsel fees and court costs.
Husband and Wife both agree that they have been
respectively advised and are aware of the contents of the
provisions of the Divorce Code, as amended, in Pennsylvania,
wherein considerations are set forth in determining an
appropriate amount, if any, to be paid in the form of alimony.
After being fully advised of the contents of the Divorce Code, as
amended, both parties voluntarily and intelligently waive and
relinquish any right to seek from the other payment for support.
alimony and maintenance.
14. MUTUA~ RELEASE
Subject to the provisions of this Agreement, each party
waives his or her right to alimony and further distribution of
property inasmuch as the parties hereto agree that this Aqreeaent
provides for an equitable distribution of their marital property
in accordance with the Oivorce Code. as amended. Subject to the
prOVisions of this Agree..nt, each party has released and dis-
charged and by thia Agreement does for himself or heraelf. and
his or her heirS, legal representative., executors,
19
administrators and assigns, release and discharge the other of
and from all causes of action, claims, rights or demands what-
soever in law or equity, which either of the parties ever had or
now has against the other, except any or all cause or causes of
action for divorce or except in any or all causes of action for
breach of any provisions of this Agreement. Each party also
waives their right to request marital counseling pursuant to
Section 3302 of the Divorce Code.
15. SUBSEOUENT DIVORCE
A decree in divorce entered by a court of competent
jurisdiction to either party shall not suspend, supersede or
affect the terms of this Agreement. Both parties agree, if
requested, to enter a Consent Order or Orders concerning the
provisions of this Agreement in the eourt of Common Pleas of
cumberland eounty, Pennsylvania, or any other Court of competent
jurisdiction, as a part of a resolution of any divorce action
filed or to be filed. This Agreement, and the terms and
conditions contained herein, as well as the enforcement of said
teras and conditions, shall be contingent upcn the granting of a
DivorCe Decree to either party by the Court of Common Pleas of
cumberland county, Pennsylvania. or any other Court of competent
jurisdiction. rurthe~or.. both p&rties hereto agree, if
requested. to execute the appropriate affidavits and consents to
:0
secure a No-fault Divorce as may be required by the Divorce Code,
as amended. Both parties agree that this Agreement may be
incorporated into a separate Court Order but shall not merge in
such order.
16. ENTIRE AGREEMENT
This Agreement contains the entire understanding of the
parties and there are no representations, warranties, covenants
or undertakings other than those expressly set forth herein.
Husband and Wife acknowledge and agree that the provisions of
this Agreement with respect to the distribution and division of
marital and separate property are fair, equitable and
satisfactory to them based on the length of their marriage and
other relevant factors which have been taken into consideration
by the parties. Both parties hereby accept the provisions of
this Aqreement with respect to the division of property in lieu
of and in full and final settlement and satisfaction of all
claims and demands that they may now have or hereafter have
against the other for equitable distribution of their property by
any court of competent jurisdiction pursuant to Section 3502 of
the Divorce Code or any amendments thereto. Husband and Wife
e.Ch voluntarily and intelligently waive and relinquish any right
to .eek . court ordered det.~ination and distribution of aaritll
I
t
property, but nothing here1n contained abatl conatitute . waiver
21
by either party of any rights to seek the relief of any court for
the purpose of enforcing 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 their respective
counsel, and each party acknowledges that the Agreement is fair
and equitable, that it is being entered into voluntarily, with
full knowledge of the assets of both parties, and that it is not
the result of any duress or undue influence. The parties
acknowledge that they have been furnished with all information
relating to the financial affairs of the other which has been
requested by each of them or by their respective counsel.
18. ADDITIONAL INSTRUMENTS
Husband and Wife 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 terms of this Agreement.
19. MODIFICATION AND WAIVER
Any modification or waiver of any of the provisions of
this Agree..nt shall be effective only if made in writing and
executed with the sam. formality as this Agreement. The failure
o! either party to insist upon strict performance of any of the
provisions of thia Agr....nt shall not be construed as a vaiver
~2
of any subsequent default of the same or similar nature. The
waiver of any term, condition, clause or provision of this
Agreement shall in no way be deemed or construed as a waiver of
any other term, condition, clause or provision of this Agreement.
20. BREACH
If either party hereto breaches any provision of this
Agreement, the other party shall have the right, at his or her
election, to sue for such breach, or seek other remedies or
relief as may be available to him or her. Both parties agree and
are aware that non-compliance with any provision of this Agree-
ment permits either party to pursue appropriate legal remedies,
including sanctions as set forth in 23 Fa. e.S.A. 13105.
Each party further hereby agrees to save and hold
harmless the other party from any and all attorneys' fees, costs
and leqal expenses and expenses that either may sustain, or incur
or become liable or answerable for. in any way whatsoever, or
shall pay upon, or in consequence of, any default or breach by
the other of any of the tens or provisions of this Agreement by
reason of which either party shall or shall be obliged to retain
or engage counsel to initiate or maintain or defend proceedings
aqainat. the other at law at equity or both or in any way what-
.oaver, provided that the party \tho seeks to re~ver such
attorney.' fees, coat. and 1eqa1 expenses and expenses aust. fint
23
be successful in whole or in part, before there would be any
liability for attorneys' fees, costs, legal expenses and
expenses. It is the specific agreement and intent of the parties
that a breaching or wrongdoing party shall bear the burden and
obliqation of any and all costs and expenses and counsel fees
incurred by the other party in endeavoring to protect and enforce
his or her rights under this Agreement.
All remedies provided by law and all remedies provided
for in this Agreement for enforcement of the Agreement shall be
deemed to be cumulative and the exercise of one remedy shall not
bar or prevent the pursuit of any other remedy and either party
may elect to pursue such remedies simultaneously and the exercise
of a remedy one or more times shall not exhaust its use or
prevent further pursuit of such remedy.
21. DESCRIPTIVE HUDINGS
The descriptive headings used herein are for
convenience only. They shall not have any effect whatsoever in
deteralninq the rights or obligations of the partie..
22. IHDEPENQ!:H'l' SEPARATE COVENANTS
It i. .peeifieally under.tood and agreed by and bet~n
the partie. hento that each paraqraph hereof shall be 4....4 to
be a .eparate end independent covenant and a,ne.ent.
23, APPL1~.t~ ~
24
IIIlllIII
Fortis Insurance Company
501 West Michigan
Milwaukee.. WI 53203
(800) 553.(654
Explanation of Benefits
"
..:..~'.,
. ......
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FORTIS
5<,.-,1rartrwsl'..ootJ<e!<lJvlO'll'
Our Customer Service Oept Is available
Monday-Friday. between the hours of 1:30am
and 6:00pm. Central Time at (800) 553-7654
CAl\ERON RILEY
225 SHOOP LANE
HALIFAX PA 17032-7921
I moUNd _
""oured 11IISS.,
IPoIIc:r.
Ia.lmNumbor:
_N_
Dele:
Cameron Riley
50495111 ~
TI-5049511'-oo1-1-01-10-oo03
214223190
22 4
I Below la an EIlpJanatIon of BenetltI for your Madlcal Cavenlge
L
Patient C_ron Rlle{ P_IIlISU: 101-80-1812
P~NMIe: Char es R Fields DOS P_ Account.:
Servica ServIce Provider Allowed I Dlacount ~ IDecIuctlbleI Copey Pay Rernarb I Amount
DesCription Date(a) etwga I Amount Amount At , Paid
00120 Mise lied bp 05/13/2004 m.oo m'oo 11651 fg'OO
01120 Mi se lied bp 05/13/2004 .00 .00 11651 .00
01203 Mise lied bp 05/13/2004 .00 .00 lI651 SO.OO
00272 Hi sc lied bp 05/13/2004 S31.oo 1.00 0657 SO.OO
TIlT AlS SI54.. SI54.. SUO
latrts
0019 Issued and unclenoritten by John Alden Ufe IftSUrInCt ~. . Fortis Healt1l MIIlber CaIpIn,y.
0657 This deIItal service/proclOire Is nit CIllIftWd under 1fU' ..sictl pl...
,.... ...-
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CHARLES R FIELDS. DDS & ASSOC
2101 ASPEN DRIVE
MECHANICSBURG. PA 17055-5508
lCJ
.\;. ,,1,\,"1
-,'
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I STATEMENT DATE
, ()6.10-04
PAY THIS A..OUtlT AGel A
$154.00 4246
__,_, ___._'H'___'___'_ _ _ __'.___."
l''''".-::
ADDRESS SERVICE REOUESTED
PAYMENT DUE DATE: 06-26-04
FOR BILLING INQUIRIES, PHONE 717-697-3400
PAGE: 1 011
.__.._._._.__.. _._.~...._..._.._..J __._ _ I
,
: SHOW AMOUNT $
" PAID HEl'te
L_.._____._______ ___.. J
:_.J".
AOORtSSEE:
1...111...111.....11...1.11...11.1....1.1...11..1.1.1.1....111
KIMBERLY S MICHAEL
225 SHOOP LANE
HALIFAX. PA 17032-7921
REMIT TO:
1."11I".11I.",1.1..1.1..1.1"1.1.11...1..1.11.,,,,.11,,11.1
CHARLES R FIELDS. DDS & ASSOC
2101 ASPEN DRIVE
MECHANICSBURG, PA 17055-5508
14133. T95& . 19Atl.fUJN00Q()44
STATEMENT
PlEASE onACH AND RElURN TOP PORTION WITH YOUR PAvMEN1'
n PIe.51l chftd. be.. it eod,..,.. IS fnc;C'tMct Ot If1SUfWlCe
U ",formatIOn tlas changed. ..,., tndlC". eh_nv-,sl on f.verw l$de
DATE PATIENT NAME DISCltIPTIOH CHAaGI PAYXDIT ctlIUlENT PATIENT
AJIOUNT AJIOUNT BALANCE BALANCE
0:/:3/04 PREVIOl:S BALA~CE 108.80 108.80
03/:3/0-i Account Check recv'd - ThanJ,; you! (4731 108.80
05/13/0-; Kimberly S (MmO Periodic om Evaluauon 46 .CO
C5.' 13 /O~ Klmberly S till In Prophyluls - Adult 57.00
05/13 JO~ Klmberly S (M1274 Four Bncwmgs 51.00
O~/13/04 TOQI (ees (or 05- 13-04 160.00 160.00
O€:/:O/O4 Klrnberl y S Insurance SW11mary:A claim of $160.m 160.00
for charges Illcurred on 05-13-114 was
sublIIitted 10 Iron WOfkers' Benelil
FWId on 05-13-04.
OS/13/04 Cameron 00120 Pmod1c Oral EvaluatJOtl 46.00
05/13/0. Cameror. 01120 Cluld Prohy i:.CO
C5,13/C4 Cameron 0!203 Top.Sod1um F1uonde ClIlld :'.0 I
C5/13 !e. Cameron 002~2 T",'O B.ttWlDgs 37.00
05/13/01 Total (ees for 05-13--114 154 . 00 314,JO
0$/:8/0. Cameron Pnmar)' IIU pmt: Foms Insurance 314 .00 154.00
COlIIpIIIy
C~llO/04 Cameron IJuuraacr SIIIIIDWY: A claim of $1 ~. 00 114.00 lS..OC
fur cllarJCS lIICumd on 115-13.<14 was
subaulled 10 Fanis IlISIIIUCe
C~ 011 05-13-04. TIIry pal4S0JM
I I
i
, I I
I
~. . .
~:u-UJlt! 1O-W,Y IO.tIAf; JO.w,y Ilm~. j ~=~l L~ I roue FROM PATIENT~
i 1114.001 $O.OOi $0.001 so,ool HU.n! un.oo' U,OO!~H"H. '154.00:
.,....~..,___,.-.._~,_~~._._"....,.__.~____~_..,..._,__~._,-..._..__"'..i.-,_...,...,...,,.,._..""'....;.,_--._...___,.l.,___~_...-__......... " JL :'r;t,~J~'!7,;:3
~ (,,~ ~ of 154 00 1$ due It\ our ~ flO iller INn {)6.2fo..()t R~ lllIrtr rd.
,,,rntJefly S M-chaeII 'ortwl den;ed C."'eflllil 04i \~'03lUte of MrYa ~ hII ~ rd
';dv~ <1enl.1ll:o_age on lhos IlIaA TlG. R~oSClI& p;iW'ty rde .l<lrIIberly S ~ per
<,'<1''5 CKr"""", has flC deI1tlll ~. tMl 1NJm p.iIt ~ lor Ib 1 t,'\l&Ul c:l S I.;i
r* ""'WC~ ply ~ (l(~ S ~ 't:rt<s11ll C:.,OllIOllS b ()l-:l(';41lo11
(I",.." S L~ 1I0..1tt\ h<lXl.,. ~ lloIlf Or" l1<If. A~ ~ ".. \It.~ So
~"",.." C"''''''',,\~,~ t\)r~:'I$ C.Slj,cl'W "'- 5154 ~ to "''''''* '""voW."".... M
[';,'J"c.;'iQ r..Ai
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n.........'n...
I PATIENT NAME DESCRIPTION CHARGE PAYMENT CURRENT PATIENT
DATE AMOUNT AMOUNT BALANCE BALANCE
1::'/::0/03 PREVIOUS BALANCE 161.00 161.00
1: :'1/03 Cameron Pnmary IDS pm\: funis Insurance 1H.QO .61.00
Company ,-- --- .;.(---- )
12/18/03 Cameron ... Insurance summary:A claim o( S 111.IMI _'!I"'~CI 161.00 161.00
, for charges Incurred on II.OK.Oj was =
SUbmitted to fonis Insurance
Company on I t.W.OJ. They paid SU.IM)
CUUDIT 10-DAY U-DAY to-DAY TOTAL IJISlJIWICI: DIFEUJ:D liouE FROM PATIENT ii
8ALAIICZ ,EIlDIJIQ AJK)UII'1'
SO.OO un.oo '0.00 $0.00 Uil.OO $0.00 $0.00 11....... un. 0011
II 'I
49.00 of y<U balance is now past due Please pay tl1is amount irnrnedialeIy. In addtion. 112.00
of y<U balance is due in OU' office no Iatef than 01..03-04. Responsible party note (Kimberly
S MIChael). F tw1IS denied CamerOl,'s 0411 2J03 date d service staling he does not have derUl
coverage on thIS plan. TLG; Responsible party note (Kimberly S MdIaeI). Kllllberly's oopay
for her (Mjt2lO3 Clataot_~ i$ V-UlO. ny; Responsible party note (Kirnberti S
MJdlae~lm'~ 1 1108IQ:H~ 149..lpar; Responsible party note (Kimberly S
Mtchael). per f flas no derUI coverage thru them. pal responsible for dos
1110&10:1 of $~5~;,
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I KENNETH R. HARII, Jr.. M,D. .( , I,.f;; 1i''i:Nb i fA.
I CATHLEEN K, SAHGlllO. 1.10 ..CllJr1 \\-~iJ'" ~ f"
I WCHAEl R GAWLJ.S. 00. 11(' ::';",.IlJ'.1i:>-JI L P4
I JANE ROWEHL ".0 ~IC' \'., ;;:w,--.,:.. [ ,PA
I ERNEST Y. JOSEF, MO .IL, 1rA:; ,\.t~f_l ,,,.&
I PAMELA J. SHlREY.Ii.S.H. C,R HI' lIC' ~I ;llJ'f.-,",!!' iN,
IDEN1SE F. HAftR. ".0 :"1(' vtJ~~"6U. ,PA.
I EUlAIETlt A, ....u:A. ..5,". C,UP LiCl "p-flC!I.rl' 8 ,PA,
lUNDA M. WOOOtH.IU.N.. C,A,NP uti SI' 0042'2 8 ;PA
DATE PHONE
GOOD HOPE FAMILY PHYSICIANS
UfHnlW>I t1<'"r,IQt' M",.Il!,..II(,'Ul,p
1830 GOOD HOPE ROAD
ENOlA PA 17025
1'7.732.8877
www.myhealth com,'GoodHopeFamllyPhYSlcl3ns
CURRENT 31 . eo 81 .90 91 . 120
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l MICHAEL R. GAWLAS, 00 tIC' C$,OO!lO'Jl-l ;PAl MI!mMf ~r,tol~' MPth<;a, Groof1
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l DENISE f. HARR. MO lO I,COOli'I!iG l IPA, 717.732-8877
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I UNOA M, WOOOlt4. MS.H.. C.A_NP l C' sP00.4212 B ,Pl., www.myhealth.comiGoooHopeFamtlvPhV&tCl8ns
DATE ~ PHONE I'NS CURR~=-_:~ 3t~OO-t__~~~~_ 91.120
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I I CATHLEEN K SANQllLO .. D t ,(.. ,"'U 'l<:,',j' l ,"A,
I MICIiAEL R. GAWLAS. D.O \1(' \l!,>-,1~,('!'1I1 ,I"
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kim & john michlel
From:
To:
Sent:
Subject:
'kim & john mlchaer <jnnic:hael@pa.net>
<rbuiIder140aol.ccm>
Tuesday, March 23, 2004 10:04 AM
LOTS OF INFOI
Dan:
1. I am mailing you a copy of earn's April b-bal11ICheduIe today.
2. Scouts: future c:ampoutp Fri. Apr 3O-May 2, 2004. Hidden Vlnay Jamboree- 800+ acouts
July 25-31,2004. Hidden V.Uay SunvnerCamp,lIite "David"
Brian Hoffman's. 717-8ll6-8981If any questions.
3. San AntDniotrlp info: Slnce it would COIl about $1200. to IIy there( 4lickel1), we're probably gonna drive thent
instead. We" get one of thole car dvd players & hit the road. Rtason mentioned, we'd have to spilt the drive
there in 2 days. We could leave Uon. Uay 3 am & stan driving home Sat May 8 am. This would give us 3 whole
days III visit them & .. Ed's graduation Frt If it is Ok with you, Cam would miss 5 days of IChoollnl1ead of 3.
We" be seeing tht country-let me know if this is alright. because I'm trying III get II-. plans 1ln8IizecI.
t"l\Summer schedule: Fri. 6/4 School ends.
V Set. 6/12 Cam & Adam to Clmden YIIrds 1Il_ OrloIeslGlants game
Thur. 6/17 earn N8Ilts to go III Jubilee day in Mechanic:lbufg (camivalIstreet fair).
7/25-7/31 Scout lIUIllITllIt' camp .,_
r;-... ..' 8130 Schoolltalts. . ~Ol< o5..,J,... .
\jfSummer" I UOO" propouI:Fri. July 2 iii Fn. Juty23rd. (3wks.) ~ oK
Frt Aug. 6 till Fri ~ (2Nks.) , ~.:2C
These are the dalls' could WOI1l out. around'lieenct of July ~week. (You could mlk III Brian
Halfman if you're intIreIlad in COI.....g to lhal)
I did"'t belt to ......;;.. your time wi CaIn. as well as aIIO keeping Cam's events pIIl._ Last yWs b-tIII
e-m ended about June 22, FYl.
6. Apnll suppolt increase: $888.75
+17.22
$70S,97due
7. earn's 2004 b-blllgur: Recaipt c:opy betng senllDday IarlDllll: $7i.48.... oflhatis S3t.7~.
In doling, pleMe ........1_ to Wf8P up Ed's bow in 31r1111l bIgS & duct.. 10 fOU can tIlrow. in your nICk bed
an nut V~,' Thanks, Kim
DICKS SPl1lTlNli GOCDS
HAARISIUlC, PA
[117] 541-5181
039 !D ES! 03113/04
SALE 325J 03: 10 PM
C4~
IC:k ~\.: : 2OC'.l1 .10
l6S25<.."ll!!~7 &:d- '9.9!!
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rue "
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Old I Ju.t !iCe .
Robm c;O\,ercd In
snow'.'!
Srl~ Hutt,,,",
(7/?)8'1~ -b'<l &1
Troop 1165 News - Man:b 10.2004
I. Cblnlle In Weekl)' Meeting lIilgbl- Small change In our Weekly Muting night. The 3'"
Wednesday ofllle monlh. our mccllng will be Thursday' e~elltng.
looking ahead thiS Impacts AmI 22 Mav 20 ~l:I1e 17 ..;
.J
So Meellnp :\larcb 17 or I B.
J, Begmmng In March. we'll be offcnng the Flrsl Aid MmlBadge. Ja\'U\'s Uncle, Kim
Malter will be leaching the badge, Kim IS an experienced EMT and is well known around the
football program In Hahfax, Rrgular allendance Is important la completlac tbls badge
over IlIe needed 4+ weeks.
4, April 24" - Hdle and PtCIltC al Rtckms Glen Stile Pari... Farmhes and fncnds m\1led. We'l\
caravan from Hahfax al 8:00 AM 10 spend the day lhere, We'll do the 4-mile hike 00 "The
Falls Tnul", have lunch and then depart for home,
195
: "';,~
~.~
5, Fature Campoats
. Friday, Apnl 3()- May 2, 201M - Kry~ Council ~ Jamboree aIIIVSR, 800<
Scouts ",,11 be there that weekend' See brIo," Rcspon..<c fonn, Cost is S20.00 per Scout.
· N."," V .11" ,- r_".. J,. 'l-1I. ,,,' "Do,.... r~ "".00 ;J;f . 0-0 .U'
$. CIO -,-
2 OtIr PIzza " Seft Prnul Sak BtaW Marcil 24! All profil aoc~ towards the Scouts l.f ,1:10 l)b.L
Camp balance Pkase 5ft" Gary Slwk for Order Forms, We'll have prizes for the lop 2
Sellen,
Dates
.
.
.
4. l..ct', laI\ abMI Sa_ r_...
4l Swnmn ('I!'lIp lqtlltJdtn \a1k} s,.-OOI Rt\Cl'\al...." J..I~ ~~ . \l. :1(1).1 .
~ AU ~'t,..h In' lY'4utml to 11I.1' l1ft r.k a ("-2 ...;r.... \uJM'! l>y . pftyiJli:tIlIl e\fl')' J CA.\!)
~. \!\!\...:h. \'lilflIt\ ft ...k.:d k' "11' an.Itlll"lllll a (,.... ny... stalmllllal all ~,'V
hL'alth '"""IN""" " \fin ,'\lrIY{1 1'Ica.'o<< \~ tllW \>f Ilw x.>tlI~ '" !1ft . hl~1I . I J.i,..
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to the Petitioner pursuant to the annual cost of IMng adjustments made under fi12(A)(ii) of the
Marital Property and Settlement Agreement (hereinafter referred to as the "Agreement'). A true
and correct copy of the Agreement Is attached to the Petitioner's Petition for Spedal Relief for
Enforcement of Marital Property and Settlement Agreement as exhibit "A".
4. The Respondent Is responsible, pursuant to fi12(A)(iII) of the Agreement, for the
extracurricular expenses incurred by the minor through his affdlallon with the Boy Scouts In the
amount of Six Dollars and 151100 ($6.15). A true and correct copy of the involce for the
extracurricular actMty expense due and owing Is attached hereto and Incorporated herein as
exhibit "B".
5. The Respondent Is responsible, pursuant to fi12(a)(v) of the Agreement, for half
of Cameron's unreimbursed medical expenses since the time of filing of the original Petition.
which totals Twenty Dollars and 01100 ($20.00). A true and correct copy of the invoice for the
unreimbursed medical expense due and owing is attached hereto and incorporated herein as
ExhibIt "C".
WHEREFORE, the Petitioner respectfully requests that this Honorable Court enter an
Order:
A. Finding the Respondent in bte8d1 of the parties' MarUI Property and
Settlemlnt Agreement;
B. Ordellllg Respondent to ~ with the I8rmI of the parties' MIrtlIII
Plqlerty by paying Nineteen HI.nnd s....tfr-8lx 00IIarI and 42/100 (11,918.42)
..-p'f 1I'1tfog his obIlgation of support tor the cant and ...,.. of his c:hid;
C. Oldle.lllQ Respondellt to be SOIety mpoIlSibIe for ~ in fuI of
Plllllooer's ~.. Ollable at'lO"..lrl feet, . OV."lr..1t of wtlich will be pnMdId to the
CourtlA"wi,og. tot I rir'O on..".,.. of _ f"tti........ or.... Court oIler.l.i.. diled1..
D. Ad~lety... PIItiIIoI... would ~ ... .. "U'iQ on lie
Pllllc.w. Am."eNd Pin -f for ~.., ....... , any, be tlMrd at.. aamt time ..
""A
and correct copies of the invoices for the unreimbursed medical expenses due and owing are attached
hereto and incorporated herein as Exhibit "B'.
8. The Respondent was notified by the Petitioner that, pursuant to section 12(A)(iii) of the
Agreement he is responsible for all of the school and sports-related extracurricular expenses Incurred by
Cameron, including expenses for summer camp, sports equipment and photographs, totaling $350.48. True
and correct copies of the invoices for the extracurricular activity expenses due and owing are attached
hereto and incorporated herein as Exhibit "Co.
9. Since April 1, 2004 the Respondent has failed to make the current $705.97 full amount due
and owing for child support by making 5 payments for the period from Marth 1, 2004 through July 1, 2004 in
the amount of $700.00, thereby making the Respondent $29.85 in arrears for that time period.
10. The Respondent has failed to pay his required August 1, 2004 child support payment, half of
the unreimbursed medical expenses in the amount of $158.00, for any of Cameron's extracurricular activities
totaling $350.48, and has failed to make payments in full for the March 1. 2004 through July 1, 2004 period
and therefore, is obligated to pay One Thousand Two Hundred Forty-Four DolIafs and 301100 ($1,244.30)
pursuant to the Agreement.
11. The Agreement further states in paragraph 20:
20. BREACH
If eittler party h4nto breaches any provision of this Agreement, the other
peI1y shall have the right. at his or her eleetion. to sue for such bte8C:h. or seek
other remedies ex relief as may be available to him or her. BoIh parties agree
end are aware that non-comptiance wlth any provision of this Agreement permits
either party to pursue apprcprIate legal remeditK, including sanctions as set forth
in 23 Pa. C.SA p105...h is the specific agreement end intent of the parties that
a breaching or wrongdoilig party shaD bear the burden and obligation of any e.1d
aM c:osts and IXl*\HS and counsel fees tnQlIl1Id by the Olher party in
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12. The lIonOlable Kevin A. Hess has previously r\lled on OlheriUuel in this case
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