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CON!tt.o'NCB P. BaUNT
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MARITAL SBTTLBMBNT AGRBB~
(rIA- -f11.v..! J
THI' AGRIIMIlNT, made this ~ day of~ r , 1997,
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by and between JAMES R. WICKS, now of Camp Hill, Cumberland
County, Pennsylvania, hereinafter referred to as "Husband",
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LINDA I,. WICKS, noW of Mechanicsburg, Cumberland County,
Pennsylvania, hereinafter referred to as "Wife""
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WITNBSSJm I
WKIRIAS, Husband and Wife were lawfully married on May 17,
1906, in Houston, Texas, and there ar~ no children born of this
ml!lrril\gll, and
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WKIRIAS, diverse unhappy marital difficulties have ar,isen
between the parties, causing them to believe that their marriage
is irretrievably broken, as a resu~t of which they have separated
and now live separate and apart from one another, the parties
being estranged due to such marital difficulties with no
reasonable expectation of reconciliation; and the parties hereto
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are desirous of settling fully and finally their respective
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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
of real and personal property; the settling of all matters between
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them relating to the past, present, or future support 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 estate,
particularly those responsibilities and rights growing out of the
marriage relationship/ and
WHBRBAS. both Husband and Wife have been fully, separately
and independently advised of their legal rights and obligations,
and each covenants that he and she has each made a full and
complete disclosure to the other of his or her respective
property, holdings and income; and
The provisions of this Agreement and their legal effect have
been fully.explained to the parties by their respective counsel.
The Wife has employed and had the benefit of counsel of DEBRA A.
DENISON, ESQUIRE, as her atto~ney. The Husband has employed and,
had the benefit of counsel of CONSTANCE P. BRUNT, ESQUIRE, as his
attorney. Each party acknowledges that he or she has received
independent legal advice from counsel of his or her selection and
that each fully understands the facts and has been fully informed
as to his or her legal rights and obligations. Each party
acknowledges and accepts that this Agreement is, under the
circumstances, fair and equitable, and that it is being entered
i.nto freely and voluntarily after having received such advice and
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with such knowledge, and that execution of this Agreement is not
the result of any duress or undue influence and that it is not the
result of any collusion or improper or illegal agreement or
agreements. In addition, each party hereto ackn?wledges that he
or she has been 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 at all marital property owned or possessed jointly
or individually by either party, counsel fees and costs of
li,tigation, and, fully knowing the same and being fully advised
of his or her rights thereunder, each party hereto still desires
to execute this Agreement, acknowledging that the terms and
conditions set forth herein 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
affecting the respective parties' rights to a divorce, alimony,
alimony pendente~, equitable distribution of all marital
property, counsel fees and costs of litigation.
NOW, THEREFORE, in consideration of the premises and of the
promises, covenants and undertakings hereinafter set forth, and
for other good and valuable consideration, the receipt of which is
hereby acknowledged by each of the parties hereto, Husband and
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Wife, each intending to be legally bound hereby, oovenant and
agree as followsr
1. SEPARATION. It shall be lawful for Husband and Wife at
all times hereafter to live separate and apart from the other, at
such place or places as he or she may from time to time choose or
deem fit. Each party shall be frp,e from J,nterference, authority
or contact by the other, as fully as if he or she were single and
unmarried, except as may be necessary to carry out the provisions
of this Agreement. Neither party shall molest the other or
attempt to endeavor to molest the other, nor compel the other to
cohabit with the other, nor in any way harass or malign the other,
'nor in any way interfer.e with the peaceful existence, separate and
apart from the other.
2. ~EQUENT DIVORCE. The parties hereby acknowledge that
Wife has filed a Complaint in Divorce in Cumberland County,
docketed to No. 96-5784 Civil Term, claiming that the marriage is
irretrievably broken under the no-fault, mutual consent provision
of Section 3301(c) of the Pennsylvania Divorce Code, The parties
hereby express their agreement that the marriage is irretrievably
broken and express their intent to immediately execute any and all
affidavits or other documents necessary for the parties to obtain
an absolute divorce pursuant to Sectiorl 3301(c) of the Divorce
Code. The parties hereby waive all rights to request Court-
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ordered counseling under the Divorce r.ode. Neither party to such
action shall seek alimony or support contrary to the provisions of
this Agreement. It is further specifically understood and agreed
by the parties that the provisions of this Agreement relating t~
equitable distribution of property of the parties are accepted by
each party as a final settlement for all purposes whatsoever, as
contemplated by the Pennsylvania Divorce Code.
should a decree, judgment or order of separation or divorce
be obtained by either of the parties in this or any other state,
country or jurisdiction, each of the parties hereby consents and
agrees that this Agreement and all of its covenants shall not be
affected in any way by any such separation or divorce; and that
nothing in any such decree, judgment, order or further
modification or revision thereof shall alter, amend or vary any
term of this Agreement, whether or not either or both of the
parties shall remarry, it being understood by and between the
parties hereto that this Agreement shall survive and shall not be
merged into any decree, judgment, or order of divorce or
separation. Notwithstanding the provisions of the Pennsylvania
Divorce Code or of any law to the contrary, none of the terms and
provisions of this Agreement shall be subject to modification by
the Court or in any fashion other than as set forth hereinafter.
It is specifically agreed, however, that this Agreement shall be
subject to enforcement under the provisions of the Pennsylvania
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reason of lSuch debts or obligations incur'red by her sinoe the date
of said separation, except as otherwise set forth here~n.
The parties acknowledge that all of ' their marital debts have
been paid in full. Wife shall assume as her sole and separate
responsibility the entire balances outstanding on the Chevy Chase
Bank Visa account 1*4246 1710 0838 5846 (having an approximate
balance of $4,000.00) and on the credit account with First Western
Bank (having an approximate balance of $3,000.00), and she shall
indemnify and save Husband harmless from any liability thereon.
5. MUTUAL RELEASES. Husband and Wife de hereby mutually
remise, release, quit-claim or forever discharge the other and the
estate of such other, for all time to come, and for all purposes
whatsoever, from any and all rights, title and interest, or clai.ms
in or against the estate of such other, of whatever nature and
wherever situate, which he or she now has or at any time hereafter
may have against such other, the estate of stich other or any part
thereof, whether arising out of any former acts, contracts,
engagements or liabilities of such other or by way of dower or
curtesy; or claims in the nature of dower or curtesy, or widow's
or widower's rights, f,mily exemption or similar allowance or
under the intestate laws; or the right to take against the
spouse's will; or the right to treat a lifetime conveyance by the
other as testamentary; or all other rights of a surviving spouse
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to participate in a deceased spouse's estate, whether ari~ing
under the laws of Pennsylvania, any state, co~monwealth or
territory of the United States, or any other countrYt or any
rights which either party may now have or at any time hereafter
have for past, present or future support or maintenance, alimony,
alimony oendente lite, counsel fees, costs or expenses, whether
arising as a result of the marital relation or otherwise, except,
and only except, all rights and agreements and obligations of
whatsoever nature arising or which may arise under this Agreement
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or for the breach of any provision hereof. Notwithstanding the
foregoing, the parties expressly reserve any claims for past or
present support or maintenance, alimony, alimony nendente ~,
counsel fees, cOAts or expenses, as have previously accrued or
hereafter accrue pursuant to an Order of Court previously or
hereafter entered. It is the intention of Husband and Wife to
give to each other by the execution of this Agreement a full,
complete and general release with respect to any and all property
of any kind or nature, real, personal or mixed, which the other
now owns or may hereafter acquire, except, and only except, all
rights and agreements and obligations of whatsoever nature arising
or which may arise under this Agreement or for the breach of any
provision hereof.
6.DIVISIbN OF HOt1SEHOLD AND PERSONAL PR9PERTY. The parties
hereto have div~ded between themselves, to their mutual
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satisfaction, all items of tangible and intangible marital
property. Neither party shall make any claim to any such items of
marital property, or of the separate personal propet'ty of either
party, which are now in the possession and/or under the control of
the other, Should it become necessary, the parties each agree to
sign, upon request, any titles or documents necessary to give
effect to this paragraph, Property shall be dnemed to be in the
possession or under the control of either party if, in the case of
tangible personal property, the item is physically in the
possession or control of the party at the time of the signing of
this Agreement, and in the case of intangible personal property,
if any physical or written evidence of ownership, such as
passbook, checkbook, policy or certificate of insurance or other
similar writing is in the possession or cont~ol of the party.
Anything to the contrary contained herein notwithstanding, Husband
and Wife sh..ll be deemed to be i.n the possession and control of
any pension or other employee benefit plans or other employee
benefits of any nature to which either party may have a vested or
contingent right or interest, apart from the provisions of the
Di.vorce Code, at the time of the signing of this Agreement.
7. REAL ESTATE ES~. The parties acknowledge that they
sold their joint marital residence in November, 1996, and that the
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proceeds thereof are contained in two escrow accounts with Dauphin
Deposit Bank, held in the names of their respective counsel. They
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further acknowledge that the combined balances in the. said
accounts are $36,997.89 aD of March 2S, 1997, after deductibn of
the sum of $3,552,00 'to pay f~deral and state income taxes due on
their joint tax returns for 1995. The parties acknowledge that
Wife has previously received an advance distribution of $5,000,00
from the net proceeds of the sale of their said marital residence,
which shall remain her sole and separate property. Wife shall
also receive as her sole and separate property the sum of
$31,659.89 from the remaining escrow proceeds, free of any claim
by Husband. Husband shall receive as his sole and separate
property the sum of $5,338.00 from the said remaining escrow
proceeds, free of any claim by Wife. Any additional interest
earned on the said accounts from March 26, 1997, through date of
final closing and distribution shall be divided equally between
the parties, The closing of the accounts and distribution set
forth herein shall be completed within thirty (30) days from
execution of this Agreement.
8. ~BHICLBS. Wife shall retain possession and ownership of
the 1993 Mercury Villager van, which is presently in her
possession, free and clear of any claim, right, title or interest
in said vehicle on the part of Husband. Husband agrees to execute
any necessary documents to transfer sole ownership of said vehicle
to Wife within thirty (30) days of the date of this Agreement.
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Husband shall retain po~session and ownership of the 1987
Ford Thunderbird, which is presently in his possession, free and
clear of any claim, right, t i,t le or interest in said vehicle on
the part of Wife,
9. DISTRIBUTION or CASH ASSBTS. STOCKS AND BONDS. Husband
shall retain the following assets as his sole and separate
property, free of any claim, right or interest by Wife~
1, MFS Growth Opportunities Fund-A, account
#05312450535 (approximate balance $6,036.31),
2. prudential Securities IRA account #OPG-R46545-04
(approximate balance $20,255,01) I
3. Commerce Bank checking account #032054835
(approximate balance $385.l4), and
4. Edison Credit Union account #321424269
(approximate balance $220.60).
Husband shall also retain any other checking and/or savings
accounts which are in his own individual name as his sole and
separate property, f~ee of any claim, right or interest by Wife.
Husband represents that he had no other checking or savings
accounts in his name prior to separation.
Wife shall retain as her sole and separate property any
checking and/or savings accounts which are in her owh individual
name, free of any claim, right or interest by Husband. This shall
expressly include the account at First Western Bank, opened by
wife prior to separation of the parties, Wife represents that she
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had no other checking or savings accounts in her name prior to
separation.
Wife shall alBa retain as her sole and separate property the
sum of $600.00 received from the sale of the parties' l6wnmower
and snowblower, following their separation.
10. LIPE INSURANCE POLICIES. Husband shall retain as his
sole and separate property, free of any claim by Wife, the
following life insurance policiesl
1. CIGNA Group Universal Life, Certificate #010010597;
2. New York Life Policy #31868576; and
3. New York Life Policy #36076360.
Husband shall be free to alter any beneficiary designations
for the said policies or to take any other action with regard to
said policies.
To the extent that is possible for him to do so, Husband
shall execute all necessary documents within fourteen (14) days of
the execution of this Agreement to transfer to Wife the Cigna
Group Insurance rider, insuring Wife's life for $25,000.00, and
she shall retain the said policy as her sole and separate property
and shall be free to alter any beneficiary designations for said
policy or to take any other action with regard to it.
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11. PENSION. PROPIT-SHARING. RETIREMENT. CREDIT UNION OR
9THER EMPLOYMENT-RELATED PLANS. Wife expressly waives and
relinquishes any claim, right, title or interest in Husband's
pension benefits earned or retirement accounts accrued as a result
of his employment with any company, including specifically without
limitation, Bayer Corporation (approximate agreed present value
$l,2, 725.04), United Gas Pipeline (now pal't of Koch Gateway
Pipeline Company) (approximate agreed total present value
$14,759,88), and Pennsylvania National Mutual Casualty Insurance
Company (approximate agreed value at separation $3,468.16).
Husband shall retain all benefits to which he is now or hereafter
entitled through any such employers or former employers, as his
sole and separate property. Wife shall promptly execute any and
all documents required by any of the said pension or retirement
plans to. confirm her said waiver of any rights she may now or
hereafter have in the respective plan as Husband's spouse or
former spouse.
12. ALIMONY., Husband shall pay to Wife alimony in the
amount of $1,300.00 per month for a period of twenty-four (24)
months, commencing on April' 1, 1997, and in the amount of
$1,200.00 per month for an additional thirty-six (36) months
thereafter. Said alimony payments shall be made through the
Cumberland County Domestic Relations Section by wage attachment.
Said alimony payments shall be non-modifiable, except as set forth
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herein. The said alimony obligation shall terminate upon the
death of eitner party or upon Wif.e's remarriage or cohabitation
with an unrelated sexual partner. Notwithstanding the foregoing,
the amount of the said alimony payments shall be subject to
reduction in the event that Husband experiences an involuntary
decrease in income by adverse job action, including demotion, lay-
off or involuntary termination, or by virtue of partial or total
disability. The reduction in the monthly alimony payments will be
pro rata to the percentage of the reduction in gros~ income he
experiences. The said alimony payments shall be deductible by
Husband and includable in Wife's income for federal income tax
purposes.
The partie~ acknowledge that there is presently outstanding
an Order for spousal support through the Domestic Relations
Section of cumberland County, Pennsylvania, docketed to No. 1118 S
1996, DR #25,877, providing for payment by Husband of spousal
support in the amount of $376.00 per week, effective October 15,
1996. The parties agree that the said spousal support Order shall
be terminated, effective March 31, 1997, and that they shall take
all necessary steps to arrange for the said termination as soon as
practicable. Husband shall withdraw his pending appeal from the
Support Order. Any sums received by the Domestic Relations
Section after April 1, 1997, shall be ~pplied and credited against
Husband's alimony obligation as set forth above. 'rhe parti.es
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further agree that Husband should have been cr.edited in the tdtal
amount of $1,750.00 for total direct payments made to Wife from
the effective date of the said spousal support Order through the
effective date of the wage attachment, and that his account has
only been credited for $1,000.00 to date. The parties further
agree that the proper amount of the arrears as of January 6, 1997,
after deduction of the aforesaid total credit for direct payments,
should have been set at $2,762.00 and authorize the Domestic
Relations Section of Cumberlan~, County to credit Husband's account
13. TAXES. By this Agreement, the partles have intended
to effectuate and by this Agreement have equally divided their
marital property, The parties have determined that such division
conforms to a right and just standard with regard to the rights
of each party. The division of existing marital property is
not, except as may be otherwise expressly provided herein,
intended by the parties to constitute in any way a sale or
exchange of assets, and the division is being effected without the
introduction of outside funda or other property not constituting
a part of the marital estate. The transfers of property set
forth herein are intended to be tax-free pursuant to ~1041 of the
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Internal Revenue Code. As a part of the equal division of the
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marital property and the marital settlement herein contained, the
parties agree to save and hold each other harmless from .all income
t~xes assessed against the other resulting from the division of
the property as herein provided.
The parties acknowledge that they have filed various joint
income tax returns during the course of their marriage. In
the event that any additional taxes, penalties or interest
are assessed as a result of any such joint return, the party
responsible for under-reporting income or claiming any improper
deduction shall indemnify and save the other party harmless from
such tax liability, penalties or interest, ~usband shall make all
joint returns in his possession available to Wife for copying upon
her request.
The parties agree that they have filed joint federal and
state income tax returns for 1996 and that the additional tax
liability believed to be due has been pa~d from the Dauphin
Deposit Escrow Accounts holding the proceeds of the sale of the
marital residence, Any refund, penalty or further liability
arising from the said joint return shall be divided equally
between the parties. The parties acknowledge that the sale of
the'ir marital residence at 23 Stone Spring Lane, Camp Hill,
Pennsylvania, was reported on the said 1996 joint tax returns and
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that the taxes due on capital gains resulting from that sale were
paid from the said escrow accounts as part of the total 1996 tax
liability.
14. MlDICAL INSURANCm.. Husband shall provide medical
insurance coverage as provided by his employer for the benefit of
Wife until the final entry of a decree in divorce. Husband shall
report the el1try of the divorce decree to his employer within ten
(10) days of his receipt of a copy of the decree.
15. ADDITIONAL INSTRUMmNTS. Each of the parties shall,
from time to time at the request of the other, execute,
acknowledge and deliver to the other party any and all further
instruments or documents that may be reasonably required to give
full force and effect to the provisions of this Agreement.
16. MODIPICATION AND WAIVER. A modification or waiver of'
any of the provisions of this Agreement shall be effective only
if made in writing and executed wich the same formality as this
Agreement. The failure of either party to insist upon the strict
performance of any of the provisions of this Agreement shall not
be construed as a waiver of any subsequent default of the same or
similar nature.
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17. BNTIRI AORIIMINT. This Agreement contains the entire
understs,nding of the parties, and there are no representations,
warranties, covenants or undertakings other than, those expressly
set forth herein.
18. DBSCRIPTIVm HEADINGS. The descriptive headings used
herein are for convenience only, They shall have no effect
whatsoever in determining the rights or obligations of the
parties.
19. INDEPENDENT SEPARATE COVENANTS. It is specifically
un~erstood and agreed by and between the parties hereto that each
paragraph hereof shall be deemed to be a separate and independent
agreement.
20. BREACH. If either party breaches any provision of this
Agreement, the other party shall have the right, at his or her
election, to sue for damages for such bre~ch or to seek such other
remedies or relief as may be available to him or her, and the
party breaching this contract shall be responsible for payment of
legal fees and costs incurred by the other in enforcing his or her
rights under this Agreenlent, or in seeking such other remedies or
relief as may be available to him or her.
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LINDA L. WICKS, I IN THI COURT or COMMON PLBAS or
I CUMBIRLAND COUNTY, PBNNSYLVANIA
Plaintiff I
v. I CIVIL ACTION - LAW
I
JAMBS R. WICKS, I NO. 96-5784 CIVIL TIRM
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Defendant I IN DIVORCE
PRAICIPB TO TRANSMIT RBCO~
TOI Lawrence B. Welker, Prothonotary
Transmit the record, together with the following infor~ation,
to the Court for entry of a divorce decree I
1. Ground for divorcel irretrievable breakdown under
Section 3301(c) of the Divorce Code.
2. Date and manner of service of the Complai,nt: 10/24/96 by
certified mail, restricted delivery.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the Affidavit of Consent
required by Section 3301(c) of the Divorce Code: By Plaintiff:
May 9, 1997; By Defendant: April 29, 1997.
(b) (1) Date of execution of the Plaintiff's Affidavit
required by Section 3301(d) of the Divorce Code: N/A
(2) Date of service of the Plaintiff's Affidavit upon
the Defendant: N/A'
4. Related claims pending: None
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6. Date and marner of s~rvice nf the Notice Of Intention To
File Praepipe To Transmit Record, cop~ of which is attached, if the
Decree is to be entered under Section 3301(d) (1) (i) of the Divorce
Code IN/A
DATElI .slf r In
ResP~ul~ ~mitted'
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CONSTANCE P. BRUNT, ESQUIRE
Supreme Court I.D. No. 29933
2941 North Front Street
Harrisburg, PA 17110 .
(717) 232-7200
Attorney for Defendant
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eonauft poatm.m.r for"',
','iitr. James R Wicks
'.\~1i3 stone sprinq Lans
':tiamp Hill, PA 17011
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C\oFFICEIWPWINIWPOOC5\oOME5TICIWICK5 WOR
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LINDA L, WICKS,
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY. PENNSYLVANIA
NO. 96-5784
Plaintiff
v.
JAMES R. WICKS.
CIVIL ACTION - LAW
[)I VORCE
Delcmdnlll
PRAEPPE TO WITHDRAW ECONOMIC CLAIMS
TO THE PROTHONOTARY
Please withdraw all economic claims tiled by Linda L Wicks in the above matter,
Respectfully Submitted,
REAGER & ADLER. PC
Date: May 6, 1997
BY'~J~~N.ESQUlRE
Attorney ID, No 66378
233\ Market Street
Camp Hill, PA 17011-4642
Telephone No. (717)763-\383
Attorneys for Plaintiff
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LlNIlA I., WICKS
I'I.AINTII+ : IN Till'. ('01110' OF COMMON PLEAS OF
: ClIMlII'I(I.ANIl ('OIlNTY, PENNSYI.VANIA
VS DOMES IK I(UAIIONS SITIION
CIVil, A('lloN. slIPPOln
MMES 1(, WicKS
11I:F!'NIMNT NO. l)(, CIVil 57H,I
OIUl.:I( (IF ('OIIRI'
AND NOW. Ihls ~ dllY nr..M1!l.., 1991, hllsclIlIlllllllhc ('nllrl's lIclcl'millllllllnlhnl
1'lninlll1's nlllnlhly' cnmlng clIpllcily/ncllllcllIlIc Is $li!A., nlllllll:l~IIdlllll's Ilhllllhly clIl'lling
clIpncily/ncllllcI'lI1c is $~.Lil., It is hCl'chy lll'dcl'cllthlltlhc I Icl~lhlnlll pn) 10 Ihc Dllmcsllc
Rclnlilllls Scclinll. ('llllrl I,rClIIlIlIlllll PIClIs, $ Illlll,ll() 1I1l111lllh pnynhlc $1.1()ll,llll IICI' mlllllh
cl1'cctlvc. -1.1.97, Mrcllrs scllll $ 12,U,,1I11 ns llr 5..11-1/7 (VV Ilh thc Insl pn)mCIII dulc llr J..:.!1:
2I. ),urc 1I11c ill fiilllMMl'.lllAIEI.Y, (,<mlclI1pl pl'nccclIings. cl'clIll hlll'cull rCI,nl'lillgllll,llus
rcrlllhllllfsct ccrtllknllnllllllll cntl'llllCC Ill' U jlldgclI1cnlll1uy hc Ih'llIlnuhc)ullcc Us IllllgUS
Dcl~ndnnl puys $ IllH,l)ll Ilcr II1l1ll1h lIlIuncurs cuch pnymcllIlIulc, I'ullllrc lllll1U~C cuch
puymculnlllill1c unll ill 1'1111 ",III ClIlIsC 1111 arrcllrs In hcclImc sllhjccIlll llI1ll1clllulc c:,lIcctlllll hy
ullllrlhc mcuus IlstclIuhnvc
I'llI' thc SUppllrtllr !.illda I.. Wic~s, This llrllcr Is 1l1ll'SllUllltllUIIUII.rCCmClll Sllhllllllcllln
Ihc Dllmcslic Rclutllllls Oflicc hv Ihc Illlrllcs 1lIl-l..1ll.'17, "hich Is hllsclllllllhc Ilurlics Murllul
Sclllcll1clIl AlI.rCCmClI1. Thc sllnuslIl SUllllllrt Ordcr Is Icrmllllllcll cfkclivc .1-.11.<)7 lVith..1lJ.l;
IIrrCUrlIlI.CS creditcll $1.H7H,llll, l(cmllilllllll.lIl'rCUrs tll hc Iluld ulthc rUlc llr$IOH,llll Ilcr mlllllh
($5ll,llll hi-"cc~lvt, Thc dcl~lIdllnl shull puy thc cnsts llr$ N/A. "hich Slllll illclullcs thc pm.
mtcd scrvicc f~c llr$ N/A. puyuhle "llhill1!LLi. duys,
Suld mllncy tll hc turncd nvcr hy thc Dllll1cstic I(clnlilllls SeelllHltll: Lilldul.. Wlc~s ,
l'uYll1clllS Illust hc mudc hy cush, chcc~ llr mlmcy ordcr, Cush puymcllls mllsl hc mudc ill
pcrsllll, All ehcc~s ulld 11H'lIe) nrders mllst hc llIudc payuhlc tllDllll1Cstic RcllltlllllS Scclillllund
lIclivcrcllllr mullclltllllllmcstle I(clutions Scctllln. 1.1 Nllrlh I hll111VCr Slrccl. p, 0, IlllX .12ll,
Curlislc,Pcllnsylvulliu 17ll13, Elich pUYll1cnlmllst hcur Y"llr Dlllllcslic 1(c1utlllIlS Illlmhcr ill
ordcr III hl' proccsscll,
IJllrcimhllrscd mcdleul cspellscs urc III hc puld N/A % hy Dcl~lldulllund N/A 'v. hy
1'lullllil1'. li!A.tll pmvidc lI1edleul Insurancc cllvcragc N/A, Wilhill.1ll lIuys ullcr thc clllry Ill'
Ihis llrdcr. 111l' li!A. shull suhlllltllllhc pCI'Sll1l huv illg cllst",ly Ill' thc child( rCllt "rillCII prollr thul
mcdicullllSlll'llllCC Cll\crnl!C hus hccllll1l1llc. Prllnr Ill' CllVCrugC shull ClllISisl. UIUlllllllllllllllllr:
( I) thc IIUIllC llrthc hcullh curc C<l\cmgc pl'llvldcrls): (2) UII) upplleuhlc Idclltlfkullllll IHllllhcrs:
(.1) ullY curds cvldcllcing cnvcm!!e: (01) thc udlll'Css III \\hleh c1uill1s shlllllll hc Illadc: (5) u
dcscriplilHlllrUII) I'estrictlllns llllllsagc, slIch as u prillI' upprmalli.r hllSpiluludmissilllls.uud Ihc
IllUIIIICr' Ill' llhlllining upprmuf: (6) u cllPY nr the hcnclit h",,~lcl "I' cm el'llgc cllnlrucl: (7) u
dcscriplillll "rull dcdllctillks und clI.puymcnls,un,1 (H) Ihc cl.pics "rnn) c1uimllll'll1s,
IMI'Ol(l^NII.UiAl. NUIKL
I'ARIILS MIISI WIIIIIN SLVLN I>A YS INH mM IIII', IJOMLS I It' RLIAIIONS
SH'THIN ^NI> TIlL (>1111'11 l'^,nll',S, IN WIH IIN(" (>I' ANY M^'ITRIAI, {'I/^N(jl: IN
('IIH'IIM'i1 ^NI.TS I(UI,V ^NII( llllF I,LVIJ, (>I SIII'I'(IR I (IR IIII'
A1IMINIS II(AIIIlN 01 I III, SIiI'I'OR I llIWI.R, INn III >IN(j, 11111 NO I IJMITUJ 10,
,n
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LOSS tm (') IANeiE OF INCOME Olt EMI'I,OYMENT ANIl CIIANOI': OF l'EttSONAl.
AIlDRESS t lit CIIANOI:, t lI' M )llltFSS t)F ANY t 'IIILI) ItH'EIVINti SIJl'PORI. A
PARTY WIIO WiLl J:lIl.1,Y I:AIIS 10 ItLPoln A MATLltlAl. CIIANtiL IN
t'lR('IIMSTANn, MA Y ilL AIlJIIIlOU) IN CONTLMI'T OF COllin, ANIl MA Y III'.
FlNEIl Olt IMPltlSI INU "
PENNSYLVANIA LA W I'IWVIIlLS IIIAI All SIIPI'ORI OIUlI'JtS SIIAll. III'
ItEVIEWW M I.LAS I oNCl. LVUtY II 11m, (I) YLMtS IF SIICII A ItLVILW IS
RH.,lIlI:Sllll BY (lNF OF 1111. I'ARIILS, II. YOII WISIITO ItEI,lIlFST A IU,VIEW ANIl
AIlJIISTMl.NT 01' YOI lit I lIt1lLIC YOII MilS IIlO IIII' FOllOWINt i: AN
lINREl'ltESU~IIJ) I'UtSON Will) WANTS 10 MOlliFY (AIlJIIST) A SlIl'l'Oln OIWFR
SIIOIlI.IJ 1'11.1'. A PLTIIION HlIt MOllll'ltAIION. nlltMS ME A VAll.Alll.E AT TilE
DOMESTIC IU'I,AlIONS OI'l'KL
A MANIlAIOIW INCOME AITACIIMl.NT WII.I,ISSIIE lINl.ESS TilE IlLFENIlANT IS
NOT IN ARltEARS Ii': I'A YMENTIN AN AMOIlNT H,lIlAl. TO OR G1tEMER TIIAN ONE
MONTII'S SlIPI'Oln Olll.ltiATION ANIl (I) TilE COlJRT FINDS TIIAT TIIEltE IS OOOD
CAliSE NOT TO ItH,lIlIRI: IMMUlIAIEINCOME WITIIIIOl.DINO; OR (2) A WRI'ITEN
ACiltEEMENT IS ItEAClIIJ) BETWITN TIIEI'ARIIES WIIICII PIWVIIlES FOlt AN
ALTERN ME AIUtANtiLMENL
DEI.INt,lIlI'.NT AltRFARMiL IlAl.ANCFS MA Y Ill'. REPORIH) TO CREDIT AOENClES.
ON AND AFTER '1'111' DATL IT IS IlIlE. LACIIIINI'AIIl SlII'I'Oln I'A YMENT SltAl.!.
(,ON'iTITlITL A JlIIlOEMLN'1 AOAINST YOIl.
IT IS FIIRTIIER ORDEREIl Ihal. upon defendanl's lililnre 10 comply with Ihis order.
delilndanlmu)' be urresled IInd hrnulIht belllre the COllrt fur II (\lIllempl hellrinll. delilndunt's
wuges. sulury, CllllllllissillllS. lind/or income mllY he lIullched in lIecurdunce with Ihe IlIw. Ihis
Order will be increused wilhoullllrlher hellrinlllo $l!LLl.umllluh until allllrrellruges arc pllil! in
full. Delilndllnl is respllnsihle Illr court eosls 1I111llces liS delermined b)" lhe Domeslic Rdlltiuns
Sceliun.
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This order shllll he eOllle Iinlllten dll)'s uller Ihe muilinll lIf Ihe nut Ice of Ihe enlry of Ihe
order tll lhe pnrties unless either Ilurl)' Iiles II wrillen demllnd wilh Ihe Domestic Rehlli'lIls
Section tllr a hearing de nllvo betllre the Conrt
Copies delivered lu Pllrties un ~,?, (J- q 'I
Consenled: '
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Plnintill"
l'lnintill's Allurney
Detilndont
Delcndllnl's Allunley
BY TI E coURT.
IlRO: Joseph M. Topichllk
ec: plnintiff
delilndunt
("lIhtllnee 1', Brunt. Esqnire
Ilehru A, Denison, Esquire
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