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PROPER'r'i SETTLEMENT
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THIS AGREEMENT, made this '1--
AGREEMENT
day of IL~~Vt?fl'f.u.tj
1996,
by and between JOHN B. MERRIS, (hereinafter called "Husband") and
CHRISTINA M. MERRIS, (hereinafter called "Wife").
WIT N E SSE T H:
WHEREAS, the parties hereto are Husband and Wife, having been
married on June 13, 1989 at Lititz, Lancaster County, Pennsylvania,
and they have no children; and
WHEREAS, difficulties have arisen between the parties as a
result of which they now desire to live separate and apart and by
this Agreement to settle all financial and property rights between
them; and
WHEREAS,
in preparing this Agreement and negotiations
contemporaneously therewith, Husband was represented by R. Mark
Thomas, Esquire, and Wife was represented Jason M. Weinstock,
Esquire; and
WHEREAS, Husband and Wife respectfully acknowledge that before
signing this Agreement they have been fully advised by their
respective counsel of their rights and obligations, or have waived
the right to be fully advised by their respective counsel of their
rights and obligations, and have read carefully and understand the
terms of this Agreement, and have freely consented to this
Agreement, believing it to be fair, just and equitable; and
WHEREAS, Husband and wife are satisfied that they understand
the value and extent of all property which would be considered
"marital property" under the pennsylvania Divorce Reform Act,
whether titled or owned separately or jointly as well as the value
and extent of nonmarital property held or expected to be held by
each other; and
NOW, THEREFORE, in consideration of the mutual promises and
undertakings set forth herein and intending to be legally bound
hereby, the parties hereto do agree as follows:
1. MUTUAL SEPARATION - Husband and Wife shall be free from
constraint or control by the other as fully as if he or she were
unmarried. Neither shall disturb, trouble and interfere in any way
with the other or with any person for associating with the other.
2. MUTUAL RELEASE Husband relinquishes his inchoate
intestate right in the estate of Wife, and Wife relinquishes her
inchoate intestate right in the estate of Husband, and each of the
parties hereto by these 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
action or suits at law or in equity, of whatsoever kind or nature,
for or because of any matter or thing done, admitted or suffered to
be done by said other party prior to and including the date hereof;
further, the parties acknowledge that all rights under the
Pennsylvania Divorce Code that are not specifically incorporated
herein are hereby expressly waived.
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3. DIVORCE - Husband has filed a Complaint in Divorce and
Equitable Distribution. The parties agree that each of them will
execute an Affidavit of Consent and a Waiver of a right to receive
a notice of intention to seek entry of a Divorce Decree. These
documents will be executed by both parties immediately after the
expiration of the 90 day waiting period from the date of service of
the Complaint.
4. EFFECT OF DIVORCE DECREE - This Agreement shall continue
in full force and effect after such time as a final decree in
divorce may be entered with respect to the parties.
5. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE - The
terms of this Agreement shall be incorporated into any divorce
decree which may be entered with respect to the parties. The Court
of Common Pleas, which may enter such divorce decree, shall retain
continuing jurisdiction over the parties and the subject matter of
the Agreement for the purpose of enforcement of any of the
provisions thereof.
6. DATE OF EXECUTION - The "date of execution" or "execution
date" of this Agreement shall be defined as the date upon which it
is executed by the parties if they have each executed the Agreement
on the same date. Otherwise, the "date of execution" or "execution
date" of this Agreement shall be defined as the date of execution
by the party last executing this Agreement.
7. PERSONAL PROPERTY - The parties have physically divided
and distributed their household goods ~nd other tangible personal
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property. They mutually agree that each shall hereafter be the
sole and separate owner of all such personalty now in their
respective possessions free and clear of all rights, claims and
interests of the other party. This agreement shall constitute a
bill of sale by and from each party to the other to document the
individual full ownerships by each party of the personalty now in
their respective possessions.
Specifically, if there is any question, the parties hereby
agree that Husband shall retain possession and ownership in full of
a 1962 Corvette which he owned prior to the marriage, and Husband
shall retain full ownership and control over individual retirement
accounts which total approximately $43,000.00, but which were owned
by Husband prior to the marriage and of which only approximately
$10,000.00 would be considered marital property.
Husband hereby agrees to make a one-time payment in the amount
of $2,500.00 cash to liif.e as part of the distribution of the
marital assets.
Wife hereby retains possession of, as well as f~ll ownership
and control over, the following pieces of equipment which are
located on the marital property:
1. Tractor
2. Manure spreader
3. Mower
Wife will retain full ownership and control over the five (5)
horses which the parties purchased during the life of the marriage
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and which are currently being boarded at the marital residenc~.
wife will retain full ownership and control over the 1990 Ford
pickup truck, and in addition, Wife will be responsible for all
payments which remain due and owing on the 1990 Ford pickup truck.
8. MARITAL RESIDENCE - Husband and Wife hold title as
tenants by the entireties to a 15 acre farm which includes a house,
barn, and garage, and which is located at 236 Brick Church Road,
Newville, Cumberland county, pennsyl vania, (the "marital
residence"). The parties hereby agree as follows with respect to
the marital residence:
A. wife will make arrangements to refinance the
outstanding mortgage obligation on the marital residence so that
the mortgage will be in her name alone and her sole responsibility,
and thereafter, Husband shall deliver to Wife a duly executed and
acknowledged Deed conveying all of Husband's right, title and
interest in and to the marital residence.
B. There is presently outstanding against the marital
residence a mortgage in favor of GMAC. Wife has advised Husband
that GMAC is willing to remove his name from the obligation
provided that he executes the necessary documents required by GMAC.
Husband agrees that he will execute such documents and Wife agrees
that she will be solely responsible for the timely payment of all
past, present and future principal, interest and other fees due
under this mortgage.
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9. DEBTS - The fOllowing debts have been identified by the
parties as marital debts:
A. 199~ Ford pickup truck
B. VISA credit card ($1,000.00)
e. Business obligation ($1,700.00)
D. J.e. Penney's card & Discover credit card
(The combined debt obligation on these two cards is
approximately $3,000.00)
Husband hereby agrees to assume the debt obligations with
respect to the business obligation in the approximate amount of
$1,700.00 and the combined J.e. Penney's and Discover credit card
indebtedness in the approximate amount of $3,000.00.
Wife hereby agrees to assume any outstanding debt obligations
due on the 1990 Ford pickup truck and the VISA credit card
obligation.
Each party hereto shall be solely responsible for the payment
of the debt obligations which they have assumed pursuant to this
Agreement. Each party agrees to hold the other free and harmless
and to indemnify the other from any and all liability which may
arise as a result of the debts assumed by the other party. Both
parties agree that, in the future, neither shall cause or permit to
be charged to or against the other any purchase or purchases which
either may hereafter make and shall not hereafter create any
engagements, debts or obligations in the name of or against each
other.
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10. ALUIONY - 'rhis Agreement does not provide for the payment
of alimony to either party. Wife hereby acknowledges that she will
not receive any alimony pursuant to this Agreement and hereby
agrees not to seek any alimony or additional spousal support in any
form whatsoever from the Husband as of the date of the execution of
this Agreement.
11. ENFORCEMENT If either party defaults in the due
performance of any of the terms, conditions and covenants of this
Agreement on his or her part to be performed, the non-defaulting
party shall have the right to SU' for specific performance or
damages for the breach of this Agreement, and the defaUlting party
shall pay the reasonable legal fees for any services rendered by
the non-defaulting party's attorney in any action or proceeding to
compel the defaulting party's due performance hereunder as well as
costs for bringing the action or proceeding.
12. EXECUTION OF DOCUMENTS - The parties agree to execute
all documents, including but not limited to, deeds of title that
are reasonably necessary to effectuate the purpose of this
Agreement. In the event that either party shall refuse or fail to
execute and/or acknowledge any such document, then the other party
shall have, and is hereby granted, the right and power to appoint
one or more times any person or persons of his or her choosing as
attorney-in-fact for the other party to so execute and acknowledge
such documents.
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13. CONTRAC'l' INTERPRETATION For purposes of contract
interpretation and for the purpose of resolving any ambiguity
herein, Husband and Wife agree that this Agreement was prepared
jointly by their respective attorneys.
14. AFTER-ACQUIRED PRQfl;IITX - Each of the parties shall
hereafter own and enjoy, independently of any claim or right of the
other, all items of property, be they real, personal or mixed,
tangible or intangible, which are acquired by him or her after
execution of this Agreement, with full power in him or her to
dispose of the same as fully and effectively, in all respects and
for all purposes, as though he or she were unmarried.
15. MISCELLANEOUS
A. This Agreement constitutes the entire agreement
between the parties, being the final and complete settlement of all
matters between them and supersedes any prior written or oral
agreements between them respecting the within subject matter.
There are no representations, agreements, arrangements or
understandings, oral or written, between and among the parties
hereto relating to the subject matter of this Agreement which are
not fully expressed herein.
B. This Agreement may not be amended, modified, altered
or revoked except in writing executed by both the parties hereto.
C. This Agreement may not be assigned by either party
without the prior written consent of the other party.
D. This Agreement may be executed in multiple
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